KEY POINTS

• The FG issued guidelines for the move to the Tax Acts 2025, effective January 1, 2026.
• Pre-2026 returns, audits and disputes stay under the repealed tax laws.
• Existing incentives remain valid until expiry, but new requests fall under the 2025 Acts.

The Federal Government has released the General Guidelines for implementing the Tax Acts 2025, setting out how the country will move from the repealed tax laws to the new framework, which takes effect on January 1, 2026. The government issued the document in Abuja on Thursday to guide taxpayers, practitioners, revenue authorities and other stakeholders through the transition.

How the transition will work

According to the guidelines, tax returns for accounting periods that end before January 1, 2026, will continue under the repealed laws, while returns due from that date onward will fall under the new regime. Moreover, the document confirms that the Tax Acts 2025, which comprise the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act, apply from their respective commencement dates.

Furthermore, the guidelines state that tax liabilities, assessments, audits, investigations, disputes and enforcement actions tied to periods before that date will be treated under the repealed laws. The document also addresses income taxes, transaction taxes, development levies, record-keeping obligations and transactions that span both regimes. In addition, it clarifies that existing incentives and exemptions remain valid until they expire, even though new and pending applications will fall under the 2025 Acts.

Clarity, fairness and certainty about the new tax regime guidelines

Speaking on the release, the Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the document provides a framework for managing transitional issues while ensuring that the new laws do not apply retrospectively. He described the enactment of the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform programme.

According to Oyedele, the guidelines rest on three principles. The guidelines are anchored on three key principles, clarity, fairness and administrative certainty. Consequently, he stressed that they would promote uniform implementation across the Nigeria Revenue Service, the State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, practitioners and taxpayers.

Ultimately, the Federal Government reaffirmed its commitment to a transparent, efficient and modern tax system that supports growth, strengthens revenue administration and encourages voluntary compliance. By spelling out how existing obligations, ongoing matters and future transactions will be handled, the guidelines aim to reduce uncertainty for businesses and improve the country’s investment climate as the reforms take hold.