No Backdating, No Surprises: FG Unveils Tax Transition Rules Ahead of 2026 Rollout

The Federal Government has released comprehensive guidelines to facilitate the transition from Nigeria’s existing tax laws to the newly enacted Tax Acts 2025, which take effect from January 1, 2026.

Issued by the Federal Ministry of Finance, the guidelines are designed to assist taxpayers, tax practitioners, revenue authorities, and other stakeholders in managing issues that may arise during the shift to the new tax framework.
The Tax Acts 2025 comprise four major laws: the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act. While the Nigeria Tax Act becomes operational on January 1, 2026, the remaining laws will take effect according to their respective commencement dates.
According to the guidelines, tax obligations relating to periods before January 1, 2026—including liabilities, assessments, audits, investigations, disputes, and enforcement actions—will continue to be governed by the repealed tax laws. Similarly, tax returns for accounting periods ending before that date will be filed under the old legal framework.
However, all tax returns due from January 1, 2026, onward will be administered under the new tax regime.
The document also provides guidance on the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions, record-keeping requirements, and transactions that extend across both the old and new systems.
The government further assured taxpayers that incentives and exemptions granted under the repealed laws will remain valid until their expiration dates. Nevertheless, new applications and pending requests will be processed in line with the provisions of the Tax Acts 2025.
Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the guidelines were developed to prevent retrospective application of the new laws while ensuring a smooth transition process.
He described the Tax Acts 2025 as a major milestone in Nigeria’s ongoing tax reform agenda, noting that the guidelines are built on the principles of clarity, fairness, and administrative certainty.
According to Oyedele, the framework is intended to ensure uniform implementation and efficient administration across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners, and taxpayers nationwide.
The Federal Government reiterated its commitment to establishing a transparent, efficient, and modern tax system that supports economic growth, strengthens revenue administration, promotes voluntary compliance, and enhances Nigeria’s investment environment.