Existing Tax Obligations to Remain Under Old Laws as Nigeria Prepares New Tax System

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The Federal Government has released comprehensive guidelines to facilitate Nigeria’s transition to a new tax regime, providing clarity for taxpayers, revenue agencies, tax consultants, and other stakeholders ahead of the implementation of the Tax Acts 2025.

The guidelines, issued on Thursday by the Ministry of Finance, outline the framework for managing the transition from the existing tax system to the new legal structure and address key issues relating to tax obligations, audits, disputes, incentives, and transactions that may span both regimes.

Speaking on the development, the Chairman of the Presidential Committee on Fiscal Policy and Tax Reforms and Coordinating Minister of the Economy, Taiwo Oyedele, said the guidelines were designed to ensure a seamless transition while minimizing uncertainty for taxpayers and tax authorities.

“The Guidelines are anchored on three key principles — clarity, fairness and administrative certainty,” Oyedele stated.

According to the framework, all tax liabilities and obligations relating to periods before January 1, 2026, will continue to be governed by the existing tax laws. Assessments, audits, investigations, disputes, and enforcement actions connected to those periods will also be handled under the repealed legal framework.

The guidelines further provide that tax returns associated with accounting periods ending before January 2026 will be filed under the current laws, while all returns due from January 1, 2026, onward will be administered under the new tax regime.

Oyedele noted that the Tax Acts 2025 comprise four major pieces of legislation introduced as part of the government’s broader tax reform agenda. These include the Nigeria Revenue Service (Establishment) Act, the Nigeria Tax Act, the Nigeria Tax Administration Act, and the Joint Revenue Board (Establishment) Act.

The government also assured businesses that existing tax exemptions and incentives granted under repealed laws will remain valid until their expiration dates, a move expected to provide stability and reassure investors who secured approvals before the reforms.

However, pending applications and new requests for tax incentives will be evaluated under the provisions of the Tax Acts 2025.

In addition, the guidelines clarify the treatment of income taxes, transaction taxes, development levies, and record-keeping obligations during the transition period, providing a roadmap for compliance as Nigeria moves toward a reformed tax administration framework.

The government said the transition measures are aimed at promoting certainty, improving tax administration, and supporting the successful implementation of the country’s ongoing fiscal reform programme.

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