Businesses gain clarity as Nigeria issues transition guidelines for historic tax overhaul

• Nigeria has released transition guidelines for implementing the Tax Acts 2025 from January 1, 2026.
• Tax liabilities, audits and disputes relating to periods before that date will remain under the old tax laws.
• Existing tax incentives and exemptions will continue until they expire, while new applications will fall under the new framework.
• The government says the reforms will simplify tax administration, improve compliance and strengthen Nigeria’s investment climate.

The guidelines, issued by the Federal Ministry of Finance, outline how tax liabilities, audits, investigations, disputes and enforcement actions that relate to periods before the commencement of the new laws will continue to be treated under the repealed tax framework.

According to the government, tax returns relating to accounting periods ending before January 1, 2026, will be filed under the previous tax laws, while returns due from that date onward will be administered under the new tax regime.

The guidelines cover a broad range of issues, including the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping obligations and transactions that span both the old and new tax systems.

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One of the key provisions is that existing tax incentives and exemptions granted under repealed laws will remain valid until their expiration dates. However, new applications and pending requests will be assessed under the provisions of the Tax Acts 2025.

Speaking on the release of the guidelines, Finance Minister and Coordinating Minister of the Economy, Taiwo Oyedele, said the document provides a framework for addressing transitional issues while ensuring that the new laws are not applied retrospectively.

He described the Tax Acts 2025 as a major milestone in Nigeria’s tax reform programme and said the guidelines establish how existing obligations, ongoing matters and future transactions will be treated under the new regime.

According to Oyedele, the framework is anchored on three key principles, clarity, fairness and administrative certainty.

The government said the guidelines are intended to support uniform implementation across the Nigeria Revenue Service, state tax authorities, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners and taxpayers nationwide.

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The transition guidelines come as Nigeria prepares to implement one of the most far-reaching tax reforms in its recent history.

The reforms were signed into law by President Bola Ahmed Tinubu as part of efforts to simplify the country’s tax system, improve revenue administration, reduce compliance burdens and create a more predictable environment for businesses and investors.

The Tax Acts 2025 comprise the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act.

Together, they are expected to reshape tax administration by harmonising key aspects of Nigeria’s tax framework and providing greater certainty for taxpayers.

The Federal Government said the reforms are aimed at building a more transparent, efficient and modern tax system that supports economic growth, encourages voluntary compliance and strengthens Nigeria’s investment climate.