The Federal Government has issued transition guidelines for the implementation
of the Tax Acts 2025, clarifying how taxpayers, tax authorities and other
stakeholders should manage obligations arising from the migration from the old
tax regime to the new framework that took effect on January 1, 2026.
This was according to a statement issued on Thursday at the Federal Ministry of
Finance. According to the ministry, the document provides direction on the
treatment of tax liabilities, assessments, audits, investigations, disputes and
enforcement actions relating to periods before and after the commencement of
the new tax laws.
“The Federal Government has issued the General Guidelines for the
implementation of the Tax Acts 2025, setting out the process for transition from
the repealed tax laws to the new tax framework effective from January 1, 2026,”
the statement read.
The ministry explained 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, would
apply from their respective commencement dates as stipulated in the laws.
It noted that tax liabilities, assessments, audits, investigations, disputes and
enforcement actions relating to periods before the commencement date would
continue to be treated under the repealed tax laws.
The guidelines further stated that tax returns relating to accounting periods
ending before January 1, 2026, would be filed under the old tax laws, while
returns due from January 1, 2026, onward would be administered under the new
framework.
The ministry added that the document also covers the treatment of income
taxes, transaction taxes, development levies, tax incentives, exemptions, record-
keeping obligations and transactions spanning both tax regimes.
It stated that tax incentives and exemptions granted under repealed laws would
remain valid until their expiration dates.
However, it added that new applications and pending requests for incentives
would be considered under the provisions of the Tax Acts 2025.
Speaking on the guidelines, the Minister of Finance and Coordinating Minister
of the Economy, Taiwo Oyedele, said the document was designed to provide
clarity on transitional issues while ensuring that the new tax laws were not
applied retrospectively.
Oyedele said, “that the document provides a framework for managing
transitional issues while ensuring that the new laws are not applied
retrospectively.”
He described the Tax Acts 2025 as a significant milestone in Nigeria’s tax
reform programme, noting that the guidelines outlined how existing obligations,
ongoing matters and future transactions would be treated under the new regime.