FG issues transition guidelines for new tax regime

The federal government has issued a set of guidelines to govern the transition from the country’s repealed tax laws to a new tax framework that took effect this year, seeking to provide certainty for taxpayers, revenue authorities and investors as Africa’s most populous economy implements one of its most extensive fiscal reform programs in decades.

The ministry of finance said Thursday that the general guidelines for the implementation of the tax Acts 2025 establish how obligations, disputes, audits, incentives and tax filings spanning both the old and new systems will be treated following the commencement of the new regime on Jan. 1, 2026.

Under the new rules, tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before Jan. 1, 2026, will continue to be administered under the repealed tax laws.

Tax returns covering accounting periods ending before that date will also be filed under the previous legal framework.

Returns that fall due from Jan. 1, 2026 onward, however, will be administered under the provisions of the new tax regime.

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The guidelines are designed to address practical issues arising from the migration to the new framework and provide direction to taxpayers, tax practitioners, federal and state revenue agencies, and other stakeholders.

Recall that the reforms are anchored on four key laws enacted as part of the government’s tax overhaul agenda: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act.

The guidance further clarifies the treatment of income taxes, transaction taxes, development levies, tax exemptions, incentives and record-keeping obligations, including transactions that extend across both tax systems.

A key provision is the preservation of existing tax incentives and exemptions granted under repealed laws. Such incentives will remain valid until their expiration dates, according to the guidelines, providing reassurance to businesses and investors that existing commitments will be honored during the transition.

New applications and pending requests for tax incentives, however, will be considered under the provisions of the Tax Acts 2025.

The release of the guidelines marks another step in the administration’s broader effort to modernise tax administration, improve compliance and expand government revenues without undermining economic growth.

Taiwo Oyedele, minister of finance and coordinating minister of the economy said the document was intended to ensure a smooth transition while preventing the retrospective application of the new laws.

“The document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively,” Oyedele said.

The minister described the Tax Acts 2025 as a major milestone in Nigeria’s tax reform program and said the guidelines provide clarity on how existing obligations, ongoing matters and future transactions will be handled under the new framework.

According to the ministry, the guidelines are built around three principles, including clarity, fairness and administrative certainty.

They are expected to support uniform implementation across the Nigeria Revenue Service, state internal revenue services, the Federal Capital Territory Internal Revenue Service, local government revenue committees and tax practitioners nationwide.

The government has presented the tax reforms as part of a wider strategy to build a more transparent and efficient fiscal system capable of supporting economic growth, improving revenue administration and enhancing the country’s attractiveness to investors.

“The Guidelines are intended to promote uniform implementation and support effective administration” across tax authorities and stakeholders nationwide, the ministry said.

Authorities said the framework would help strengthen voluntary compliance while reducing uncertainty for businesses navigating the transition to Nigeria’s new tax regime.