The federal government has issued comprehensive guidelines to manage the transition from Nigeria’s repealed tax laws to the country’s new tax framework, providing clarity on how obligations, incentives and disputes spanning both systems will be handled.
The transition guidelines, released on Thursday by the Federal Ministry of Finance, follow the implementation of a new tax regime that took effect on January 1, 2026, after the enactment of a series of tax reform laws designed to modernise revenue administration and strengthen compliance.
According to the ministry, tax liabilities, audits, investigations, disputes and enforcement matters relating to periods before the commencement of the new regime will continue to be governed by the repealed tax laws.
This means that ongoing tax matters tied to previous accounting periods will not be affected by the new legislation.
The guidelines further state that tax returns for accounting periods ending before January 1, 2026, must be filed under the old legal framework, while obligations arising from that date onwards will be subject to the provisions of the new tax laws.
The government explained that the transition framework was developed to address practical challenges associated with moving from one tax system to another and to promote consistency in implementation across tax authorities nationwide.
Nigeria’s tax reforms are anchored on four key legislations: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act.
A major feature of the guidelines is the protection of existing tax incentives and exemptions granted under the repealed laws.
The government said such incentives would remain in force until their expiration dates, a move aimed at reassuring businesses and investors that previously approved commitments would be honoured.
However, applications for new tax incentives, as well as pending requests yet to be concluded, will be assessed in line with the provisions of the new tax framework.
Speaking on the development, Minister of Finance and the Coordinating Minister of the Economy, Taiwo Oyedele said the guidelines were carefully designed to ensure a seamless transition without applying the new laws retrospectively.
He noted that the framework provides a clear structure for addressing transitional issues while safeguarding taxpayers from retroactive implementation of the reforms.
Oyedele described the Tax Acts 2025 as a landmark achievement in the administration’s fiscal reform programme, adding that the transition arrangements would provide certainty for both taxpayers and tax administrators.
The ministry said the principles of fairness, clarity and administrative certainty guide the framework.
It also contains provisions covering the treatment of development levies, record-keeping obligations, tax exemptions and other compliance requirements under the new regime.
Officials said the guidelines would facilitate 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.
The government has maintained that the broader tax reform agenda is intended to improve revenue generation, encourage voluntary compliance and create a more predictable environment for businesses without undermining economic growth.
According to the ministry, the transition framework is expected to reduce uncertainty for taxpayers, businesses and investors while supporting the effective administration of Nigeria’s new tax system.
