Nigeria’s Tax Laws Take Shape as FG Issues Transition Directives

From Victor Osula, Abuja

The Federal Government has issued the General Guidelines for the implementation of the Tax Acts 2025, setting out how taxpayers, practitioners, and revenue authorities should move from the repealed tax laws to the new tax framework that took effect from January 1, 2026.

The guidelines, issued by the Federal Ministry of Finance, are meant to give direction on a range of issues arising from the shift between the old regime and the new one.

They cover four laws making up the Tax Acts 2025 — the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act, each of which applies from its own commencement date as enacted.

The Nigeria Tax Act, 2025, specifically takes effect from January 1, 2026.

Under the framework, tax liabilities, assessments, audits, investigations, disputes, and enforcement actions tied to periods before that date will continue to be handled under the repealed tax laws.

Similarly, returns for accounting periods ending before January 1, 2026, will be filed under the previous tax laws, while returns falling due from January 1, 2026, onward will be administered under the new framework.

The document also addresses the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations, and transactions that span both the old and new tax regimes.

Existing tax incentives and exemptions granted under the repealed laws will remain in place until their expiration dates. New applications and pending requests, however, will be considered under the provisions of the Tax Acts 2025.

Speaking on the release of the Guidelines, 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 are not applied retrospectively.

He described the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform programme, noting that the Guidelines set out how existing obligations, ongoing matters, and future transactions will be treated under the new regime.

The Head of Information and Public Relations Unit of the Ministry of Finance, Efe Ovuakporie, in a statement on Thursday, quoted the Minister as saying that the Guidelines are anchored on three key 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.

The Government reaffirmed its commitment to building a transparent, efficient, and modern tax system that supports economic growth, strengthens revenue administration, encourages voluntary compliance, and improves Nigeria’s investment climate.

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