The federal government has released guidelines governing the transition from the old tax framework to the Tax Acts 2025, clarifying how outstanding tax liabilities, ongoing investigations, active audits, pending disputes, and enforcement actions relating to periods before January 1, 2026 will be handled under the new system.
The guidelines, issued by the Federal Ministry of Finance and addressed to the Nigeria Revenue Service, State Internal Revenue Services, FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners, and taxpayers nationwide, establish that the new Tax Act applies from January 1, 2026 for the Nigeria Tax Act, with tax returns covering accounting periods ending before that date to be filed under the previous laws and returns due from January 1, 2026 onward to be administered under the new framework.
Finance Minister Taiwo Oyedele said the guidelines were anchored on three principles: clarity, fairness, and administrative certainty. He said the document was designed to ensure the new laws were not applied retrospectively while providing all parties with a clear understanding of how transitional matters would be treated. He said existing tax incentives and exemptions granted under the repealed laws would remain in place until their expiration dates, while new applications and pending requests would be considered under the new framework. He described the Tax Act 2025 as a significant milestone in Nigeria’s tax reform program and said the guidelines were intended to promote uniform implementation across all revenue authorities, reduce disputes arising from ambiguity about which rules applied to which transactions, and support effective administration of what he described as a modern, transparent, and
