Nigeria’s new tax regime takes shape as FG releases transition guidelines ahead of 2026 rollout.
The Federal Government has released transition guidelines for the implementation of the Tax Acts 2025, outlining how taxpayers, revenue authorities and other stakeholders should navigate the shift from existing tax laws to Nigeria’s new tax framework.
The guidelines, issued by the Federal Ministry of Finance, provide direction on the treatment of tax matters arising before and after the commencement of the new laws, which take effect from January 1, 2026.
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 law will take effect from its respective commencement date as enacted, with the Nigeria Tax Act becoming operational on January 1, 2026.
The guidelines state that tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before the commencement date will continue to be governed by the repealed tax laws.
Similarly, tax returns for accounting periods ending before January 1, 2026, will be filed under the previous legal framework, while returns due from that date onward will be administered under the new regime.
The document also provides guidance on 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 systems.
Under the transition arrangements, existing tax incentives and exemptions granted under repealed laws will remain valid until their expiration dates. However, new applications and pending requests will be assessed under the provisions of the Tax Acts 2025.
Speaking on the release of the guidelines, Taiwo Oyedele, Minister of Finance and Coordinating Minister of the Economy, said the document was designed to address transitional issues while ensuring that the new tax laws are not applied retrospectively.
According to the minister, “the document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively.”
He added that the Tax Acts 2025 represent “a significant milestone in Nigeria’s tax reform programme,” noting that the guidelines outline how “existing obligations, ongoing matters and future transactions will be treated under the new regime.”
Oyedele said the guidelines are anchored on three key principles: “clarity, fairness and administrative certainty.”
The ministry said the guidelines are intended to support uniform implementation of the new tax framework across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners and taxpayers nationwide.
The release comes as Nigeria prepares to implement a broad package of tax reforms aimed at restructuring tax administration and providing a new legal framework for revenue collection and compliance beginning in 2026.
