FG Releases Transition Guidelines for Tax Acts 2025 Ahead of January 2026 Implementation

Taiwo Oyedele

The Federal Government has released the General Guidelines for the implementation of the Tax Acts 2025, providing a roadmap for the transition from Nigeria’s repealed tax laws to the new tax framework scheduled to take effect from January 1, 2026.

The guidelines, issued on Thursday in Abuja, are designed to assist taxpayers, tax practitioners, revenue authorities, and other stakeholders in navigating issues that may arise during the shift from the existing tax regime to the new system.

A major provision of the guidelines is that tax returns relating to accounting periods ending before January 1, 2026, will continue to be filed and assessed under the repealed tax laws. However, all tax returns due from January 1, 2026, onward will be governed by the new tax framework established under the Tax Acts 2025.

According to the document, the Tax Acts 2025 comprise four key pieces of legislation: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act.

The guidelines state that each law will take effect according to its legally established commencement date, with January 1, 2026, specifically designated as the implementation date for the Nigeria Tax Act, 2025.

“Tax liabilities, assessments, audits, investigations, disputes and enforcement actions relating to periods before that date will be treated under the repealed tax laws,” the document stated.

The guidelines also address the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations, and business transactions that span both the old and new tax systems.

A significant provision is the protection of existing tax incentives and exemptions already granted under the repealed laws. These incentives will remain valid until their approved expiration dates.

However, any new applications for tax incentives, as well as pending requests yet to be approved, will be reviewed and determined in accordance with the provisions of the Tax Acts 2025.

Speaking on the release of the guidelines, the Chairman of the Presidential Committee on Fiscal Policy and Tax Reforms, Taiwo Oyedele, described the document as an important framework for managing transitional issues while ensuring that the new laws are not applied retroactively.

He noted that the enactment of the Tax Acts 2025 represents a major milestone in Nigeria’s ongoing tax reform programme and provides a modernised structure for tax administration across the country.

According to Oyedele, the guidelines are built on three fundamental principles: clarity, fairness, and administrative certainty.

“The Guidelines are intended to promote uniform implementation and support effective administration across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners and taxpayers nationwide,” he said.

The Federal Government reiterated its commitment to creating a transparent, efficient, and modern tax system capable of supporting economic growth, strengthening revenue generation, encouraging voluntary compliance, and improving Nigeria’s attractiveness as an investment destination.

Officials believe the new framework will provide greater certainty for businesses and individuals while streamlining tax administration and reducing ambiguities that have historically affected tax compliance and enforcement.