The Federal Government has issued comprehensive guidelines for implementing the Tax Acts 2025, outlining how taxpayers and revenue authorities should transition from the repealed tax laws to Nigeria’s new tax framework, which took effect on January 1, 2026.
The guidelines, released in Abuja on Thursday, provide clarity on the treatment of tax obligations, assessments, audits, incentives, exemptions and ongoing transactions during the transition period.
According to the document, tax returns relating to accounting periods ending before January 1, 2026, will continue to be filed and administered under the repealed tax laws. However, all tax returns due from January 1, 2026, onward will be governed by the new tax framework.
The government explained that the guidelines are intended to assist taxpayers, tax practitioners, revenue authorities and other stakeholders in addressing issues arising from the migration to the new tax regime.
The document states that the Tax Acts 2025, comprising the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act, will apply from their respective commencement dates as provided by law.
It further clarified that tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before January 1, 2026, will continue to be handled under the repealed tax laws.
New Guidelines
The guidelines also provide provisions for the administration of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements and transactions spanning both the old and new tax systems.
Existing tax incentives and exemptions granted under the repealed laws will remain valid until their expiration dates. However, new applications and pending requests for incentives will be assessed in accordance with the provisions of the Tax Acts 2025.
Speaking on the release of the guidelines, Chairman of the Presidential Committee on Fiscal Policy and Tax Reforms, Taiwo Oyedele, described the document as a crucial framework for managing transitional issues while ensuring the new laws are not applied retrospectively.
He noted that the enactment of the Tax Acts 2025 represents a major milestone in Nigeria’s tax reform agenda and provides a modern legal foundation for revenue administration.
According to him, the guidelines are built on three core principles: clarity, fairness and administrative certainty.
“The Guidelines are intended to promote uniform implementation and support effective administration across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners and taxpayers nationwide,” he said.
The Federal Government reiterated its commitment to establishing a transparent, efficient and modern tax system aimed at boosting economic growth, strengthening revenue generation, encouraging voluntary compliance and improving Nigeria’s investment climate.
Key Highlights of the Guidelines
- Old tax laws will apply to accounting periods ending before January 1, 2026.
- New tax laws will govern returns due from January 1, 2026.
- Existing tax incentives and exemptions will remain valid until expiration.
- New and pending incentive applications will be reviewed under the Tax Acts 2025.
- Ongoing audits, investigations and disputes relating to previous periods will continue under repealed laws.
- The guidelines seek to ensure clarity, fairness and certainty during the transition.
