Transition Guidelines for the Tax Acts 2025: Providing Clarity Amid Emerging Uncertainty.

 

Introduction

On 18 June 2026, the Federal Ministry of Finance issued the General Transition Guidelines for the Tax Acts 2025 (the “Guidelines”) pursuant to Section 144 of the Nigeria Tax Administration Act 2025 (“NTAA”) and Section 200 of the Nigeria Tax Act, 2025 (“NTA”). The Guideline is intended to provide a framework for the transition from Nigeria’s repealed tax laws to the new tax regime established under the Tax Acts 2025. Primarily, they aim to ensure consistency, prevent retrospective application of the new laws, and provide clarity on the treatment of transactions, obligations, disputes and compliance matters that straddle the transition period.

Notably, the release of the Guidelines comes at a critical time as taxpayers have grappled with questions regarding the applicable law for the tax returns due in 2026, particularly for companies with accounting periods ending on 31 December 2025. While the Guidelines seek to settle these questions, recent communications reportedly issued by the Nigeria Revenue Service (“NRS”) to certain taxpayers have generated fresh debate regarding whether assessments due in 2026 should be administered under the repealed laws or the new tax regime.

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