The Federal Government has issued comprehensive guidelines to facilitate the transition from Nigeria’s repealed tax laws to the new tax framework that came into effect in 2026.
Released on Thursday by the Federal Ministry of Finance, the guidelines provide clarity on how tax obligations, audits, disputes, incentives, and filings that span both the old and new systems will be managed during the transition period.
The new tax regime officially took effect on January 1, 2026, following the implementation of a series of tax reform laws aimed at modernising revenue administration and strengthening tax compliance across the country.
How Existing Tax Matters Will Be Handled
According to the ministry, tax liabilities, audits, investigations, disputes, and enforcement actions relating to periods before January 1, 2026, will continue to be administered under the repealed tax laws.
Likewise, tax returns covering accounting periods that ended before the commencement date will be filed under the previous legal framework, while obligations arising from January 1, 2026, onward will be governed by the new tax laws.
Providing Certainty for Taxpayers and Businesses
The government explained that the transition guidelines were developed to address practical concerns arising from the shift to the new system and to ensure consistent implementation by tax authorities nationwide.
The reforms are anchored on four key legislations:
- Nigeria Revenue Service (Establishment) Act
- Nigeria Tax Act
- Nigeria Tax Administration Act
- Joint Revenue Board (Establishment) Act
The guidelines also clarify how tax incentives, exemptions, development levies, and record-keeping requirements will be treated under the new regime.
A major provision ensures that tax incentives and exemptions granted under the previous laws will remain valid until their scheduled expiration dates.
The government said this measure is intended to reassure businesses and investors that commitments made under the former tax framework will be respected.
However, any new applications or pending requests for tax incentives will be assessed under the provisions of the new tax laws.
“No Retrospective Application”
The Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the transition framework was designed to guarantee a smooth migration to the new tax system without applying the laws retroactively.
“The document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively,” he said.
Oyedele described the Tax Acts 2025 as a major milestone in the government’s fiscal reform agenda, adding that the framework would provide certainty for both taxpayers and tax administrators.
According to the ministry, the guidelines are built on the principles of clarity, fairness, and administrative certainty.
Part of Nigeria’s Wider Tax Reform Agenda
The transition framework forms part of Nigeria’s broader tax reform programme, which aims to create a more efficient, transparent, and growth-focused revenue system.
Government officials said the guidelines will support uniform implementation across the:
- Nigeria Revenue Service
- State Internal Revenue Services
- Federal Capital Territory Internal Revenue Service
- Local Government Revenue Committees
- Tax practitioners and consultants
The government maintains that the reforms are designed to strengthen voluntary tax compliance, improve revenue generation, and create a more predictable business environment without placing unnecessary burdens on economic activity.
According to the ministry, the framework is expected to reduce uncertainty for businesses and investors while supporting the effective implementation of Nigeria’s new tax regime.
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