FG Gives Workable Framework Between Old, New Tax Regimes
Dr. Nafisat Makinɗe, Abuja

The Federal Government has issued guidelines for implementing the Tax Acts 2025, outlining how taxpayers and revenue authorities will transition from existing tax laws to a new regime that takes effect Jan. 1, 2026.
The guidelines, contained in a statement by Efe Ovuakporie, Director of Press & Public Relations at the Federal Ministry of Finance, clarify the treatment of tax obligations, assessments, audits, disputes and enforcement actions during the transition period.
Under the framework, tax matters relating to periods before Jan. 1, 2026, will remain subject to the repealed laws, while obligations arising from that date will be administered under the new tax regime.
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. Tax returns for accounting periods ending before Jan. 1, 2026, will be filed under existing laws, while those ending on or after that date will be processed under the new framework.
The provisions also address the treatment of income taxes, transaction taxes, development levies, tax incentives, exemptions and transactions spanning both tax regimes. Existing incentives and exemptions granted under repealed laws will remain valid until their expiration dates, while pending and new applications will be considered under the Tax Acts 2025.
The framework is expected to provide certainty for businesses and taxpayers by clarifying how ongoing audits, disputes, filing obligations and incentives will be treated during the transition.
Minister of Finance and Coordinating Minister of the Economy, Taiwo Oyedele, said the framework would address transitional issues while ensuring the new laws are not applied retrospectively. He described the Tax Acts 2025 as a major milestone in Nigeria’s tax reform agenda, anchored on the principles of clarity, fairness and administrative certainty.
The government said the reforms are aimed at strengthening revenue administration, improving compliance, enhancing transparency and supporting economic growth.

