Nigerian Govt releases guidelines for transition to new tax regime
The Federal Government has released detailed guidelines to manage Nigeria’s transition to a new tax regime, setting out how taxpayers, revenue agencies, consultants and other stakeholders will adjust to the new legal and administrative framework.
The guidelines, issued on Thursday by the Ministry of Finance, are aimed at reducing uncertainty during the transition period and clarifying how existing obligations, ongoing audits, disputes, incentives and transactions spanning both regimes will be treated.
According to the government, the framework addresses key implementation concerns arising from the introduction of the new tax laws, particularly issues linked to pre-existing tax liabilities, pending assessments and overlapping transactions that may cut across both regimes.
Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the guidelines were designed to ensure a smooth transition without disrupting compliance or creating confusion for taxpayers and revenue authorities.
“The Guidelines are anchored on three key principles — clarity, fairness and administrative certainty,” Oyedele said.
He explained that tax liabilities and obligations relating to periods before January 1, 2026, will continue to be governed by the existing tax laws, even after the new regime takes effect. He added that assessments, audits, investigations, disputes and enforcement actions tied to pre-2026 periods will remain under the repealed legal framework.
The minister also clarified that tax returns linked to accounting periods ending before January 2026 will still be filed under the current laws, while all returns due from January 1, 2026, onward will fall under the new tax structure.
He noted that the Tax Acts 2025 comprise four major laws introduced under Nigeria’s tax reform agenda, including the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act.
The guidelines further state that all existing tax exemptions and incentives granted under repealed laws will remain valid until their original expiration dates, a move intended to provide certainty for businesses and prevent disruption to approved investment plans.
However, it added that applications still under consideration, as well as new requests for tax incentives, will now be assessed strictly under the provisions of the Tax Acts 2025.
The framework also provides clarification on the treatment of income taxes, transaction taxes, development levies and record-keeping obligations during the transition period, as authorities seek to ensure a coordinated shift into the new tax system without disrupting revenue administration or compliance processes.
