Federal Government releases guidelines for transition to new tax regime

•Clarifies pre-2026 tax obligations

By Emma Ujah, Abuja Bureau Chief

The Federal Government has issued the General Guidelines for implementing the Tax Acts 2025, detailing how the transition from the repealed tax laws to the new framework will occur, effective January 1, 2026.

A major provision of the guidelines is that tax returns for accounting periods ending before January 1, 2026, will continue to be filed under the repealed tax laws, while returns from January 1, 2026 onward will be processed under the new regime.

Issued in Abuja on Thursday, the Guidelines give direction to taxpayers, tax practitioners, revenue authorities, and other stakeholders on managing issues arising from the transition.

Under the Guidelines, 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 apply from the respective commencement dates as enacted in each law, in particular, January 1, 2026 for the Nigeria Tax Act, 2025.

The document further states that “tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before that date will be treated under the repealed tax laws.”

The Guidelines also address 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.

It clarified that existing tax incentives and exemptions granted under the repealed laws will remain valid until their expiration dates. However, new applications and pending requests will be considered under the provisions of the Tax Acts 2025.

Speaking on the release of the Guidelines, the Minister of Finance and Coordinating Minister of the Economy, Mr. 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 enactment of the Tax Acts 2025 as a significant milestone in Nigeria’s tax reform programme, noting that the Guidelines clearly set out how existing obligations, ongoing matters and future transactions will be treated under the new regime.

According to the Minister, “The Guidelines are anchored on three key principles – clarity, fairness and administrative certainty.”

He added: “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 Federal 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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