By Chike Ofili
The Federal Government has released comprehensive guidelines for the implementation of the Tax Acts 2025, providing clarity on how Nigeria will transition from the existing tax framework to a new regime scheduled to take effect from January 1, 2026.
The guidelines, issued on Thursday in Abuja, set out the rules that will govern tax administration during the transition period and clarify how taxpayers, revenue authorities, and other stakeholders should handle obligations spanning both the old and new tax systems.
A key provision of the framework states that tax returns relating to accounting periods ending before January 1, 2026, will continue to be filed and assessed under the repealed tax laws, while returns due from January 1, 2026, onward will be administered under the new tax regime.
According to the document, the Tax Acts 2025 comprise the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act, each taking effect on the commencement dates stipulated in the respective legislation.
The guidelines specifically designate January 1, 2026, as the commencement date for the Nigeria Tax Act, 2025, while clarifying that tax liabilities, audits, investigations, assessments, disputes, and enforcement actions relating to periods before that date will continue to be governed by the repealed laws.
The framework also provides guidance on the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements, and transactions that cut across both tax regimes.
To provide certainty for businesses and investors, the government stated that existing tax incentives and exemptions granted under the repealed laws would remain valid until their expiration dates. However, fresh applications and pending requests will be processed under 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, Mr. Taiwo Oyedele, described the document as a critical framework for managing transitional issues and ensuring that the new tax laws are not applied retrospectively.
He said the enactment of the Tax Acts 2025 marked a major milestone in Nigeria’s ongoing tax reform programme and would help establish greater certainty for taxpayers and revenue authorities alike.
According to Oyedele, the guidelines are built around three core principles—clarity, fairness, and administrative certainty.
He noted that the framework is intended to promote uniform implementation and support efficient tax administration across the Nigeria Revenue Service, State Internal Revenue Services, the Federal Capital Territory Internal Revenue Service, Local Government Revenue Committees, tax practitioners, and taxpayers nationwide.
The Federal Government reaffirmed its commitment to building a transparent, efficient, and modern tax system capable of supporting economic growth, improving revenue generation, encouraging voluntary compliance, and strengthening Nigeria’s attractiveness as an investment destination.