Taxpayers will not face retrospective application of Nigeria’s new tax laws, the Finance Ministry said on Thursday, as it issued detailed guidelines for the transition from the old regime to the Tax Acts 2025 framework, which took effect on January 1, 2026.
The guidelines clarify that all tax liabilities, assessments, audits and disputes relating to periods before the commencement date will be treated under the repealed laws, providing certainty for businesses and individuals navigating the reform.
The document provides a framework for managing transitional issues while ensuring that the new laws are not applied retrospectively, Finance Minister Taiwo Oyedele said in a statement provided by the ministry spokesperson, Efe Ovuakporie.
Tax returns for accounting periods ending before January 1, 2026, will be filed under the previous tax laws, while returns for periods ending after that date will be administered under the new framework, the ministry said.

The guidelines also specify that existing tax incentives and exemptions granted under repealed laws will remain valid until their expiration dates, while new applications will be considered under the new Tax Acts 2025.
Oyedele described the Tax Acts 2025 as “a significant milestone in Nigeria’s tax reform programme,” adding that the guidelines are anchored on “clarity, fairness and administrative certainty.”
The document covers the treatment of income taxes, transaction taxes, development levies, record-keeping obligations and transactions that span both regimes.
The guidelines are intended to promote uniform implementation across the Nigeria Revenue Service, State Internal Revenue Services, the FCT Internal Revenue Service, Local Government Revenue Committees, tax practitioners and taxpayers nationwide, the ministry said.
The government reaffirmed its commitment to building “a transparent, efficient and modern tax system that supports economic growth, strengthens revenue administration, encourages voluntary compliance and improves Nigeria’s investment climate,” the statement added.
FEDERAL MINISTRY OF FINANCE
PRESS RELEASE
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The Federal Government has issued the General Guidelines for the implementation of the Tax Acts 2025, setting out…
— Taiwo Oyedele (@taiwoyedele) June 18, 2026
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