The Federal Government has issued detailed guidelines for the implementation of the new tax laws introduced under the Tax Acts 2025, setting out the rules that will govern the transition from the old tax regime to the newly established framework that came into effect on January 1, 2026.
The guidelines were announced in a statement released on Thursday by the Head of Information and Public Relations Unit at the Federal Ministry of Finance, Efe Ovuakporie.
According to the ministry, the document provides direction on how taxpayers, tax authorities, and other stakeholders should manage tax obligations that span both the former and current tax systems.
The government explained that the Tax Acts 2025 consist of the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act.
These laws form the foundation of Nigeria’s modernized tax framework and are expected to reshape tax administration across the country.
Guidelines Clarify Treatment of Existing Tax Obligations
Under the transition framework, tax liabilities, assessments, audits, investigations, disputes, and enforcement actions relating to periods before January 1, 2026, will continue to be handled under the repealed tax laws.
This provision is intended to ensure a smooth transition and prevent confusion among taxpayers and revenue agencies.
The ministry further stated that tax returns linked to accounting periods ending before the commencement date will still be filed under the old tax regime.
However, all returns due from January 1, 2026, onward will be administered according to the provisions of the new tax laws.
In addition, the guidelines address several critical areas, including income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements, and transactions that overlap both tax regimes.
The Federal Government also confirmed that tax incentives and exemptions granted under the previous laws will remain valid until their approved expiration dates.
However, fresh applications and pending requests for incentives will now be assessed under the provisions of the Tax Acts 2025.
Oyedele Highlights Fairness and Certainty in New Tax Laws
Speaking on the release of the guidelines, the Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, emphasized that the document was designed to provide certainty and transparency during the transition process.
According to Oyedele, “the document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively.”
The minister described the Tax Acts 2025 as a major milestone in Nigeria’s ongoing tax reform efforts. He noted that the guidelines clearly outline how existing obligations, ongoing tax matters, and future transactions will be treated under the new framework.
Oyedele added that the transition process is guided by three key principles: clarity, fairness, and administrative certainty. These principles, he said, are intended to help taxpayers understand their responsibilities while enabling tax authorities to implement the reforms consistently.
The Ministry of Finance stated that the guidelines are expected to promote uniform application of the new tax laws 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.
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The government reiterated its commitment to building a transparent, efficient, and modern tax system capable of supporting economic growth, strengthening revenue collection, encouraging voluntary tax compliance, and improving Nigeria’s attractiveness to investors.
The release of the transition guidelines marks another significant step in the implementation of the new tax laws, which authorities believe will transform tax administration and compliance processes while creating a more predictable and business-friendly tax environment across Nigeria.



