Almost one year to the day after President Bola Ahmed Tinubu signed the comprehensive Tax Reform Acts into law, the Federal Government on Thursday issued detailed guidelines to ensure a smooth transition to the new tax regime, effective January 1, 2026.
The General Guidelines for the implementation of the Tax Acts 2025, released by the Federal Ministry of Finance, provide clarity on how taxpayers, practitioners, and revenue authorities should navigate the shift from the old tax laws to the new framework comprising the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act.
President Tinubu assented to the four bills on June 26, 2025, marking what many described as the most significant overhaul of Nigeria’s tax system in decades.
The new laws aim to simplify compliance, eliminate multiple taxation, broaden the tax base, and create a more business-friendly environment.
Exactly 12 months later, the government has now published the long-awaited transition manual. According to the guidelines:
- All tax liabilities, assessments, audits, investigations, disputes, and enforcement actions relating to periods before January 1, 2026 will continue to be governed by the repealed (old) tax laws.
- Tax returns for accounting periods ending before January 1, 2026, will be filed under the previous regime, while those ending on or after that date will fall under the new Tax Acts.
- Existing tax incentives and exemptions granted under the old laws will be honoured until their expiry dates. However, new applications and pending requests will be processed under the 2025 Acts.
- Transactions spanning the transition date will be handled according to specific rules outlined in the guidelines to avoid ambiguity.
Mr. Taiwo Oyedele, minister of Finance and Coordinating Minister of the Economy, who has been central to the tax reform process, welcomed the release of the document.
He described the Tax Acts 2025 as “a significant milestone” in Nigeria’s tax reform journey and emphasised that the guidelines are anchored on three core principles: clarity, fairness, and administrative certainty.“
The guidelines ensure that the new laws are not applied retrospectively,” the Minister said.
“They provide a clear framework for managing transitional issues while protecting existing obligations and ongoing matters.”
Stakeholders have generally welcomed the move, viewing it as a reassurance to businesses and investors who had expressed concerns about uncertainty during the transition.
The guidelines are expected to promote uniform implementation across the Nigeria Revenue Service (NRS), State Internal Revenue Services, the FCT Internal Revenue Service, and Local Government Revenue Committees.
The Federal Government reiterated its commitment to building a transparent, efficient, and modern tax system that supports economic growth, encourages voluntary compliance, and strengthens Nigeria’s investment climate.
With less than six-and-a-half months to the commencement date of January 1, 2026, the timely release of these guidelines is seen as a critical step in preparing the nation for the new tax era.
Tax practitioners and businesses have been advised to familiarise themselves with the document to ensure seamless compliance.
