The Federal Government has released guidelines to govern the transition from Nigeria’s repealed tax laws to the new tax framework that came into effect this year.
The guidelines, issued on Thursday by the Federal Ministry of Finance, are intended to clarify how tax obligations, audits, disputes, incentives and filings that span both the old and new systems will be handled during the transition period.
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The new tax regime took effect on 1 January 2026 following the enactment of a package of tax reform laws aimed at modernising revenue administration and improving compliance.
According to the ministry, liabilities, audits, investigations, disputes and enforcement actions relating to periods before the commencement of the new regime will continue to be administered under the repealed tax laws.
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Similarly, tax returns covering accounting periods that ended before 1 January 2026 will be filed under the previous legal framework, while obligations arising from that date onward will be governed by the new laws.
Providing certainty for taxpayers
The government said the guidelines were developed to address practical issues arising from the transition and to ensure consistency in implementation across tax authorities.
The reforms are anchored on four major legislations: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act and the Joint Revenue Board (Establishment) Act.
The guidance also outlines how existing tax incentives, exemptions, development levies and record-keeping requirements will be treated under the new system.
One of the key provisions preserves tax incentives and exemptions granted under repealed laws until their expiration dates.
The government said the measure is intended to provide reassurance to businesses and investors that commitments made under the previous framework will be honoured.
However, new applications and pending requests for tax incentives will be considered under the provisions of the new tax laws.
‘No retrospective application’
The Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the guidelines were designed to ensure a smooth migration to the new system without applying the laws retrospectively.
“The document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively,” he said.
Mr Oyedele described the Tax Acts 2025 as a significant milestone in the government’s fiscal reform agenda, noting that the transition framework would provide certainty for taxpayers and tax administrators alike.
According to the ministry, the guidelines are built around the principles of clarity, fairness and administrative certainty.
Part of broader tax reforms
The release of the transition framework marks another step in Nigeria’s ongoing tax reform programme, which the government says is aimed at creating a more efficient, transparent and growth-oriented revenue system.
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Officials said the guidelines would support 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 consistently argued that the reforms are intended to strengthen voluntary tax compliance, improve revenue collection and create a more predictable business environment without stifling economic activity.
According to the ministry, the framework is expected to reduce uncertainty for businesses and investors while supporting the effective administration of Nigeria’s new tax regime.
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