FG issues transition guidelines for implementation of new tax law

By Seun Ibiyemi

The Federal Government has issued transition guidelines to guide the implementation of the Tax Acts 2025, clarifying how taxpayers, tax authorities and other stakeholders are to manage obligations arising from the migration from the old tax regime to the new framework, which took effect on January 1, 2026.

According to a statement issued on Thursday by the Head of Information and Public Relations Unit at the Federal Ministry of Finance, Efe Ovuakporie, the guidelines provide direction on the treatment of tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before and after the commencement of the new tax laws.

The ministry explained that the General Guidelines set out the process for transitioning from repealed tax laws to the new tax framework, ensuring clarity on how obligations will be handled under both regimes.

It noted that the Tax Acts 2025—comprising the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act—will apply according to their respective commencement dates.

Under the guidelines, tax liabilities, assessments, audits and enforcement actions relating to periods before January 1, 2026, will continue to be treated under the repealed laws.

It also stated that tax returns for accounting periods ending before the effective date will be filed under the old system, while returns from January 1, 2026, onward will be administered under the new framework.

The document further covers income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations and transactions that span both tax regimes.

It added that existing tax incentives and exemptions granted under repealed laws will remain valid until their expiration, while new applications will be considered under the new framework.

Speaking on the guidelines, the Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the document was designed to ensure clarity on transitional issues and prevent retrospective application of the new tax laws.

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He described the reform as a major milestone in Nigeria’s tax administration overhaul, noting that the framework is anchored on principles of clarity, fairness and administrative certainty.

The ministry added that the guidelines are intended to ensure uniform implementation 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.

It reaffirmed the government’s commitment to building a transparent and efficient tax system that supports economic growth, improves revenue generation and enhances Nigeria’s investment climate.

The release of the guidelines marks another key step in the ongoing implementation of the Tax Acts 2025, which introduced major reforms expected to reshape tax administration and compliance across the country.