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MINISTER OF FINANCE

OF THE REPUBLIC OF INDONESIA

COPY
REGULATION OF THE MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA
NUMBER 17/PMK.03/2013
CONCERNING
AUDIT PROCEDURES
BY THE GRACE OF GOD ALMIGHTY
MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA,
Considering : a.

whereas the provision regarding the audit procedures has been


set out in the Regulation of the Minister of Finance Number
199/PMK.03/2007 concerning Tax Audit Procedures as it has
been amended lastly with Regulation of the Minister of Finance
Number 82/PMK.03/2011;

b.

whereas the provision regarding audit on the Taxpayer who apply


for tax overpayment refund request and continued with the
preliminary evidence audit of criminal act in the field of taxation is
has been set out in the Regulation of the Minister of Finance
Number 191/PMK.03/2007 concerning the Issuance of Tax
Assessment Letter On Tax Overpayment Refund Request Against
The Taxpayer which is Being Audited On the Preliminary Evidence
of Criminal Act in Taxation;

c.

whereas the provision, as referred to in letter a, is also related to


the provision regarding the sealing procedure in order of tax audit
which is currently regulated in the Regulation of the Minister of
Finance
Number
198/PMK.03/2007
concerning
Sealing
Procedures In Order of Audit in Taxation;

d.

whereas by the issuance of Governmental Regulation Number 74


Year 2011 concerning Procedures for Rights Implementation and
Obligations Compliance of Taxes, it is necessary to adjust on the
provisions regarding tax audit procedures, disclosure procedures
for the untruth filling of the Tax Return Statement, procedures for
the issuance of tax assessment letter on tax overpayment refund
request against the Taxpayer which is being audited on the initial
evidence of criminal act in taxation;

e.

whereas based on the considerations, as referred to in letter a,


letter b, letter c, and letter d, as well as to implement the
provisions of Article 17B clause (1a), Article 30 clause (2), and
Article 31 clause (1) of Law Number 6 Year 1983 concerning
General Tax Provisions and Procedures as several times amended
lastly with Law Number 16 Year 2009 and as well as Article 8,

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2clause (8) of Governmental Regulation Number 74 Year 2011


concerning Procedures for Rights Implementation and Obligations
Compliance of Taxes, it is necessary to stipulate the Regulation of
the Minister of Finance concerning Audit Procedures;
In the view
of

: 1.

Law Number 6 Year 1983 concerning General Tax Provisions and


Procedures (State Gazette of the Republic of Indonesia Year 1983
Number 49, Supplement to the State Gazette of the Republic of
Indonesia Number 3262) as it has several times amended lastly
with Law Number 16 Year 2009 (State Gazette of the Republic
Indonesia of 2009 Number 62, Supplement to the State Gazette of
the Republic of Indonesia Number 4999);

2.

Governmental Regulation Number 74 Year 2011 concerning


Procedures
for
Rights
Implementation
and
Obligations
Compliance of Taxes (State Gazette of the Republic of Indonesia
Year 2011 Number 162, Supplement to the State Gazette of the
Republic of Indonesia Number 5268);
BE IT HEREBY RESOLVED:

To enact

: REGULATION OF THE MINISTER OF FINANCE CONCERNING AUDIT


PROCEDURES.
CHAPTER I
GENERAL PROVISIONS
Article 1
In this Ministerial Regulation, some terms shall be defined as follow:
1.

Law on General Tax Provisions and Procedures hereinafter


referred to as the KUP LAW is Law Number 6 Year 1983
concerning General Tax Provisions and Procedures as several
times amended lastly by Law Number 16 Year 2009.

2.

Audit is a series of activities to collect and process data,


information, and/ or evidence that objectively and professionally
carried out based on an audit standard to test the compliance
fulfillment of tax obligations and/ or for other purposes in order to
implement the provisions of the law and regulation of taxation.

3.

Field Audit is an audit conducted in the residence or domicile of


the Taxpayer, in the Taxpayer business location or selfemployment, and/ or in other places that are considered
necessary by the Tax Auditor.

4.

Office Audit is an Audit which is conducted at the office of the


Directorate General of Taxation.

5.

Verification is a series of activities of the fulfillment examination of


the subjective and objective obligation or the tax calculation and
payment, upon a request by the Taxpayer or based on the tax

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3data and information which held or obtained by the Director


General of Taxes, in order to issue a tax assessment letter,
publish/ delete a Taxpayer Identification Number and/ or
solidified/ revoke the Taxable Enterprise Confirmation.
6.

Tax Auditor shall be the Civil Servant in the Directorate General of


Tax or the expert who is appointed by the Director General of Tax,
which was given the task, authority, and responsibility to carry
out the Audit.

7.

Tax Audit Identification is an ID issued by the Director General of


Tax which is a proof that the person named on the ID card is a
Tax Auditor.

8.

Tax Audit Warrant, hereinafter referred to as the SP2, shall be an


order letter to conduct an Audit in order to examine the fulfillment
compliance of tax obligations and/ or for other purposes in order
to implement the provisions of the tax legislation.

9.

Field Audit Notification Letter is a notice regarding the Field Audit


implementation in order to examine the fulfillment compliance of
tax obligations and/ or for other purposes in order to implement
the provisions of the tax legislation.

10. Summons Letter In Terms of Office Audit is the summons


regarding the Office Audit implementation in order to examine the
fulfillment compliance of tax obligations and/ or for other
purposes in order to implement the provisions of the tax
legislation.
11. Bookkeeping is a recording process which is carried out regularly
to collect data and financial information which is including assets,
liabilities, capital, income and expenses as well as the amount of
cost and delivery of goods or services, which closed by the
preparation of financial statements in the form of balance sheet
and income statement for the Fiscal Year period.
12. Data that is electronically managed means the data in electronic
form, which is generated by a computer and/ or other electronic
data processing and stored on disks, compact disks, tape backup,
hard disk, or other electronic storage media.
13. Book, Notes, and Documents Depository are a place held by a
Taxpayer, an archive or a document storage company and/ or
held by other parties.
14. Sealing is an act of placing a seal on a particular place or room as
well as moving assets and/ or fixed assets that is used or
reasonably suspected of being used as a place or a tool to keep
books or records, documents, including electronically managed
data and other objects.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-415. Audit Working Paper, hereinafter abbreviated as KKP, means the


clear and detailed notes made by the Tax Auditor regarding Audit
procedures, which are taken the data, information, and/ or
evidence gathered, examination performed and conclusions drawn
with respect to the Audit implementation.
16. Notification of Tax Audit Findings, hereinafter abbreviated as the
SPHP, means letter that contains findings of the Audit includes
items that are corrected, the correction value, basic corrections,
temporary calculation of the tax due principal amount and
temporary calculation of administrative sanctions.
17. Audit Result Final Discussion is the discussion between the
Taxpayer and the Tax Auditor on Audit findings whose result is
stated in the acknowledgement of the Audit result final
discussions, signed by both parties and contains basic correction
of either approved or not approved principal of tax payable, and
the calculation of administrative sanctions.
18. Audit Quality Assurance Team means the team established by the
Director General of Tax in order to discuss the Audit result, which
has not been agreed between the Tax Auditor and the Taxpayer in
the Audit Result Final Discussion in order to produce a qualified
Audit.
19. Audit Report, hereinafter abbreviated as the LHP, is a report that
contains the implementation and results of the Audit organized by
the Tax Auditor in succinctly and clearly and in accordance with
the scope and purpose of Audit.
20. Short Audit Report, hereinafter referred to as the Short LHP, is a
report regarding the Audit termination without proposed the
issuance of tax assessment.
21. Preliminary Evidence Audit is an Audit that is conducted to obtain
preliminary evidence of the alleged crime had occurred in the field
of taxation.
22. Re-Audit is the Audit conducted on Taxpayer who has been issued
the tax assessment letter from the results of previous Audit for the
type of tax and tax period, part of the fiscal year, or the same
fiscal year.
23. Audit Questionnaire is a form that contains a number of
questions and assessment by the Taxpayer related to the Audit
implementation.
CHAPTER II
AUDIT PURPOSES
Article 2

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5Director General of Tax shall be authorized to conduct an Audit in


order to examine the fulfillment compliance of tax obligation and/ or
for other purposes in order to implement the provisions of the tax
legislation.
CHAPTER III
AUDIT FOR EXAMINING THE FULFILLMENT COMPLIANCE
OF TAX OBLIGATION
Part One
Scope, Criteria, and Type of Audit
Article 3
The scope of the Audit to examine the fulfillment compliance of tax
obligations may include one, some, or all type of taxes, for either one
or more Tax Period, part of the Fiscal Year, or the Fiscal Year in
previous years or the current year.
Article 4
(1) Audit to examine the fulfillment compliance of tax obligation
should be conducted to the Taxpayer who applies for tax
overpayment refund request as referred to in Article 17B of Law of
KUP.
(2) Audit to examine the fulfillment compliance of tax obligations
could be done in terms of fulfilling the following criteria:
a. Taxpayer submits the Tax Return that states the overpayment,
in addition to apply for a tax overpayment refund as referred
to in clause (1);
b. Taxpayer who has been given a preliminary tax overpayment
refund;
c. Taxpayer who submits the Tax Return that states losses;
d. Taxpayer performs a merger, consolidation, division,
liquidation, dissolution, or will leave Indonesia for ever;
e. Taxpayer perform a changing of accounting book or
bookkeeping method or due to a revaluation on fixed assets;
f.

Taxpayer does not deliver or delivered the Tax Return but


beyond the time limit as set out in the warning letter which is
selected to conduct an Audit based on risk analysis, or

g. Taxpayer who submits the Tax Return that is selected to


conduct an Audit based on risk analysis.
Article 5

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6(1) Audit to examine the fulfillment compliance of tax obligations, as


referred to in Article 4, shall be performed with Field Audit or
Office Audit Types.
(2) On the Audit, as referred to in Article 4 clause (1), shall be
conducted with the Office Audit, in the case of the overpayment
refund request is applied by the Taxpayer who meets the following
requirements:
a. Taxpayers financial statement for the audited Fiscal Year is
audited by a public accountant or the financial statement of
one of the last two (2) Fiscal Years before the audited Fiscal
Year is has been audited by a public accountant, with an
unqualified opinion, and
b. Taxpayer is not being perform an Preliminary Evidence Audit,
investigation, or prosecution of tax criminal act, and/ or the
Taxpayer within 5 (five) years has never been convicted due to
a criminal act in the field of taxation.
(3) On the Audit with the criteria, as referred to in Article 4 clause (2)
letter a, letter b, letter c, letter d, and letter e, the determination of
type of the Audit shall be set out by the Director General of Tax.
(4) On the Audit with the criteria, as referred to in Article 4 clause (2)
letter f and letter g, shall be performed with the type of Field
Audit.
(5) In terms of the Office Audit is found the indication of transaction
related to transfer pricing and/ or other specific transactions that
indicate the existence of a modified financial transaction, the
implementation of Office Audit shall be changed into the Field
Audit.
Part Two
Audit Standard
Article 6
(1) Audit to examine the fulfillment compliance of tax obligations
should be performed in accordance with the Audit standard.
(2) The Audit standard, as referred to in clause (1), shall be applied
as a measure of the Audit quality that constitutes the minimum
compliance that should be achieved in implementing the Audit.
(3) The Audit standard, as referred to in clause (1), should include
the Audit general standard, Audit implementation standard, and
Audit results and reporting standard.
Article 7

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7(1) Audit general standard constitutes personal nature standard and


associated with the Tax Auditor requirements.
(2) The Audit shall be carried out by Tax Auditor who has fulfilled
these following requirements:
a. have gained technical education and training as well as having
adequate skills as a Tax Auditor;
b. using their skills in carefully and closely;
c. honest and clean of despicable acts and always prioritizing the
interests of the state, and
d. obey to various provisions of the legislation in the field of
taxation.
(3) In the event that it is necessary, the Audit as referred to in clause
(2), could be carried out by the expert from outside the Directorate
General of Tax who is appointed by the Director General of Tax.
Article 8
The Audit Implementation to examine the fulfillment compliance of tax
obligations should be performed in accordance with the Audit
implementation standard, namely:
a.

Audit implementation should be preceded with good preparation


in accordance with the Audit purposes, which at least includes
collecting and studying data of the Taxpayer, making the Audit
plan (audit plan), and making the Audit program (audit program),
as well as receive a careful supervision;

b.

Audit is carried out by conducting an examination based on the


methods and techniques in accordance with the Audit program
(audit program) that had been developed;

c,

Audit findings should be based on sufficient competent evidence


and under the provisions of the tax legislation;

d.

Audit shall be carried out by a Tax Auditor team that consists of a


supervisor, a team leader, and one or more team members, and in
a certain circumstances the team leader can also serve as a
member;

e.

Tax Auditor team, as referred to in letter d could be assisted by


one or more person who have a particular expertise, both come
from the Directorate General of Tax, as well as those coming from
institutions outside the Directorate General of Taxation who has
been appointed by the Director General of Tax, as the experts
such as translator, expert in information technology, and lawyer;

f.

if necessary, Audit to examine the fulfillment compliance of tax

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8obligations could be carried out together with an Auditor team


from other agencies;
g.

The Audit could be carried out at the office of the Directorate


General of Taxation, residence or domicile of the Taxpayer, place
of business or self-exployment of the Taxpayer, and/ or any other
place that is deemed necessary by the Tax Auditor;

h.

The Audit shall be carried out at working hours and if necessary it


could be continued beyond the working hours, and

i.

The Audit implementation shall be documented in the form of


KKP.
Article 9

The Audit activities to examine the fulfillment compliance of tax


obligations should be documented in the form of KKP, as referred to in
Article 8 letter i, in regard with the following matters:
a.

KKP shall be prepared by the Tax Auditor and functions as:


1) evidence that the Audit has been carried out in accordance
with the Audit implementation standard;
2) substance in performing Audit Result Final Discussion with
the Taxpayer regarding the Audit findings;
3) as a Basis in the making of LHP;
4) sources of data or information for the resolution of the
objection or appeal which is applied by the Taxpayer, and
5) as a reference for subsequent Audit.

b.

KKP should provide an overview of:


1) Audit procedures that are carried out;
2) data, information, and/ or evidence obtained;
3) examination that has been conducted, and
4) conclusion and other matters that are deemed necessary in
relation with the Audit.
Article 10

The Audit activities to examine the fulfillment compliance of tax


obligations should be reported in the form of LHP that is prepared in
accordance with the Audit result reporting standard, namely:
a.

LHP is drafted in succinctly and clearly, containing the scope or


items that are examined according to the Audit purposes,
contains the Tax Auditor conclusions supported by strong

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-9findings regarding the existence or absence of deviation against


taxation legislation, and contains disclosure of other information
associated with the Audit.
b.

LHP to examine the fulfillment compliance of tax obligations at


least contain:
1) assignment of the Audit;
2) Taxpayer identity;
3) Taxpayer bookkeeping or recording;
4) fulfillment of tax obligations;
5) available data/ information;
6) borrowed books and documents;
7) examined material;
8) description of the Audit results;
9) overview of the Audit results;
10) calculation of tax payable, and
11) Tax Auditor conclusion and proposal.
Part Three
Tax Auditor Obligation and Authorization
Article 11

In conducting the Audit to examine the fulfillment compliance of tax


obligations, the Tax Auditor shall be obliged to:
a.

submit the Field Audit Notification Letter to the Taxpayer in terms


of the Audit is conducted by Field Audit type or a Summons Letter
in terms of the Audit is conducted by Office Audit type;

b.

show Tax Auditor Identification and SP2 to the Taxpayer when


performing an Audit;

c.

show a letter that contains Tax Auditor team changing to the


Taxpayers if the membership composition of the Tax Auditor team
is changed;

d.

perform the meeting with the Taxpayer in order to provide


explanation regarding:
1) reason and purposes of the Audit;
2) Taxpayer rights and obligations
implementation of the Audit;

during

and

after

the

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 10 3) Taxpayer rights to apply for discussion with the Audit Quality


Assurance Team in the event that there are any Audit results
that have not been agreed between the Taxpayer and the Tax
Auditor during the Audit Results Final Discussion, and
4) Taxpayer obligation to fulfill the demand of books, records,
and/ or documents which became the basis of accounting or
bookkeeping, and other documents, which borrowed from the
Taxpayer;
e.

write down the results of the meeting, as referred to in letter d, in


the acknowledgement of the meeting with the Taxpayer;

f.

submit SPHP to the Taxpayer;

g.

give the right to the Taxpayers to be present the Audit Results


Final Discussion at predetermined time;

h.

submit an Audit Questionnaire to the Taxpayer;

i.

guide the Taxpayer in fulfilling their tax obligation in accordance


with the provisions of the tax legislation by submitting advice in
writing;

j.

return books, notes, and/ or documents that is utilized as a basis


of accounting or records, and other documents that borrowed
from the Taxpayer, and

k.

conceal to other party who are not entitled to everything known or


disclosed to them by the Taxpayer for the Audit.
Article 12

(1) In conducting the Audit to examine the fulfillment compliance of


tax obligations by Field Audits, the Tax Auditor shall be
authorized to:
a. view and/ or borrow books, records, and/ or documents that
became the basis of accounting or bookkeeping, and other
documents relating with the earned income, business
activities, self-employed Taxpayer, or the tax payable object;
b. access and/ or download the data that managed electronically;
c. enter and inspect place or space, tangible and / or intangible
assets which is suspected or reasonably suspected to be used
for storing books, records, and/ or documents that became
the basis of accounting or bookkeeping, and other documents,
money and/ or goods thatc could give clues regarding the
obtained income, business activities, self-employment
Taxpayer, or the tax payable object;

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 11 d. demand the Taxpayers to provide assistance


smoothness of the Audit, such as in the form of:

for

the

1) provide manpower and/ or equipment at the expense of the


Taxpayer if in accessing the data that maintained
electronically is require an equipment and/ or special
expertise;
2) provide assistance to the Tax Auditor in opening the
tangible good and/ or intangible good, and/ or
3) provide a special room in which the Field Audit is performed
in terms of the Audit is conducted on the Taxpayer place;
e. conduct the Sealing of place or a particular space as well as
tangible good and / or intagible good;
f.

request an oral and/ or written information from the


Taxpayer; and

g. request information and/ or evidence needed from the third


parties who have relationship with the audited Taxpayer
through the head of the unit of Audit executor.
(2) In conducting the Audit to examine the fulfillment compliance of
tax obligations by Office Audit, the Tax Auditor is authorized to:
a. summon the Taxpayer to come to the office of the Directorate
General of Tax using a Summon For fOffice Audit;
b. view and/ or borrow books, records, and / or documents
which became the basis of accounting or bookkeeping, and
other documents relating with the obtained income, business
activities, self-employed Taxpayer, or the tax payable object;
c. demand the Taxpayer
smoothness od Audit;

to

provide

assistance

for

the

d. request an oral and/ or written information from the


Taxpayer;
e. borrow the KKP that is made by public accountants through
the Taxpayers, and
f.

request information and/ or evidence needed from the third


party who have relationship with the audited Taxpayer
through the head of the unit of Audit executor.
Part Four
Rights and Obligations of The Taxpayer
Article 13

In implementing the Audit to examine the fulfillment compliance of tax


obligations, the Taxpayer shall be entitled to:

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 12 a.

ask the Tax Auditor to show the Tax Auditor Identification and the
SP2;

b.

ask the Tax Auditor to give a Notification Letter of Field Audit in


terms of the Audit is conducted in Field Audit type;

c.

ask the Tax Auditor to show a letter that contains Tax Auditor
team changing if the membership composition of the Tax Auditor
team is changing;

d.

ask the Tax Auditor to provide an explanation of the reasons and


purposes of the Audit;

e.

receive the SPHP;

f.

attend at the Audit Results Final Discussion at predetermined


time;

g.

apply for discussion with the Audit Quality Assurance Team, in


the event that there are any Audit results, which have not been
agreed between the Taxpayer and the Tax Auditor during the
Audit Results Final Discussion, and

h.

give an opinion or an assessment of the Audit implementation by


the Tax Auditor by filling the Audit Questionnaire.
Article 14

(1) In the Audit implementation to examine the fulfillment compliance


of tax obligations by Field Audit types, the Taxpayer shall be
obliged to:
a. show and/ or lend books, records, and / or documents which
became the basis of accounting or bookkeeping, and other
documents relating with the earned income, business
activities, self-employed Taxpayer, or the tax payable object;
b. provide a chance to access and/ or download data that
managed electronically;
c. provide a chance to enter and inspect place or space, tangible
and/ or intangible good that is allegedly or reasonably
allegedly utilized for storing books, records, and/ or
documents which became the basis of accounting or
bookkeeping, and other documents, money and/ or goods that
could give clues regarding the earned income, business
activities, self-employed Taxpayer, or the tax payable object
and lend it to the Tax Auditor;
d. provide assistance for the smoothness of Audit, which could
include:
1) provide manpower and/ or equipment at the expense of the

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 13 Taxpayer if in accessing the data that managed


electronically is required an equipment and/ or special
expertise;
2) provide assistance to the Tax Auditor in opening the
tangible good and/ or intangible good; and/ or
3) provide special room in which the Field Audit performed in
terms of the Audit is conducted at the Taxpayers place;
e. submit written response upon SPHP; and
f.

provide the required oral and/ or written information.

(2) In the Audit implementation to examine the fulfillment compliance


of tax obligation with the Office Audit type, the taxpayer shall be
obliged to:
a. fulfill the summon to come attending the Audit in accordance
with predetermined time;
b. show and/ or lend books, records, and/ or documents that
became the basis of accounting or bookkeeping, and other
documents associated with the obtained income, business
activities, self-employed Taxpayer, or the tax payable object;
c. provide assistance for the smoothness of Audit;
d. submit written response upon the SPHP;
e. lend the KKP that is made by public accountants, and
f.

provide the required oral and/ or written information.


Part Five
Audit Period
Article 15

(1) Audit to examine the fulfillment compliance of tax obligation shall


be conducted within the Audit period that includes:
a. examination period, and
b. Audit Results Final Discussion and reporting period.
(2) In the event that the conducted Audit is Field Audit, the
examination period, as referred to in clause (1) letter a, shall be at
no longer than 6 (six) months, commencing from the Field Audit
Notification Letter delivered to the Taxpayer, their representative,
authority, employee, or an adult family members from the
Taxpayer, until the date when the SPHP delivered to the Taxpayer,
their representatives, proxy, employee, or adult family member of
the Taxpayer.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 14 (3) In the event that the conducted Audit is Office Audit, the
examination period, as referred to in clause (1) letter a, shall be no
longer than 4 (four) months from the date the Taxpayer, its
representative, proxy, employee, or adult family member of the
Taxpayer came to fulfill the Summon for the Office Audit until the
date at which the SPHP submitted to the Taxpayer, its
representative, proxy, employee, or adult family member of the
Taxpayer.
(4) Audit Result Final Discussion and reporting period, as referred to
in clause (1) letter b, shall be no longer than 2 (two) months,
commencing from the date at which the SPHP delivered to the
Taxpayer, its representative, proxy, employee, or adult family
member of the Taxpayer until the date of LHP.
Article 16
(1) Field Audit examination period, as referred to in Article 15 clause
(2), could be extended for maximum period of 2 (two) months.
(2) Extension of Field Audit examination period, as referred to in
clause (1), shall be conducted in terms of:
a. Field Audit is extended to the other Tax Period, part of the
Fiscal Year, or other Fiscal Year;
b. there is confirmation or requests of data and/ or information
to any third party;
c. Field Audits scope covers all types of taxes; and/ or
d. based on consideration of Head of Audit executor unit.
(3) Field Audit examination period, as referred to in Article 15 clause
(2), which in cooperation with:
a. Taxpayer of Oil and Gas Contract Contactor;
b. Taxpayer in a business group, or
c. Taxpayer who is indicated comitting a transfer pricing
transactions and/ or other specific transactions which
indicate the existence of financial transaction manipulation,
could be extended for maximum period of 6 (six) months and
could be done for no longer than 3 (three) times in accordance
with the time needed to conduct the examination.

Article 17

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 15 (1) Office Audit examination period, as referred to in Article 15 clause


(3), could be extended for a maximum period of 2 (two) months.
(2) Extension of the Office Audit examination period as referred to in
clause (1) shall be conducted in terms of:
a. Office Audit is Extended to other Tax Period, Part of Fiscal
Year, or other Fiscal Year;
b. there is confirmation or requests of data and/ or information
to third party;
c. Office Audis scope covers all types of taxes; and/ or
d. based on consideration of head of Audit executor unit.
Article 18
In terms of the extension of Field Audit, as referred to in Article 16, or
Office Audit, as referred to in Article 17, head of Audit executor unit
should give the written notification of examination period of extension
to the Taxpayer.
Article 19
(1) If the extension of the Field Audit examination period, as referred
to in Article 16 clause (1) or clause (3), or the extension of the
Office Audit examination period, as referred to in Article 17 clause
(1), has been expired, the SPHP should be delivered to the
Taxpayer.
(2) In terms of the Audit is carried out due to the Taxpayer applies for
tax overpayment refund request, the period, as referred to in
Article 15, Article 16, and Article 17, should regard to the tax
overpayment refund request settlement period as referred to in
Article 17B of Law of KUP.
Part Six
Audit Completion
Article 20
Field Audit or Office Audit to examine the fulfillment compliance of tax
obligations shall be completed with the manners as follow:
a.

terminating the Audit by making the Summary of LHP, or

b.

making LHP, as a basis for the issuance of tax assessments letter


and/ or Tax Collection Letter in accordance with the provisions of
the legislation of taxation.
Article 21

Completion of Audit by making the Summary of LHP, as referred to in

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 16 Article 20 letter a, shall be conducted in terms of:


a.

Taxpayer, its representative, proxy, employee, or adult family


member of the Audited Taxpayer:
1) is not found within the period of 6 (six) months from the date
of Field Audit Notification Letter is issued; or
2) does not fulfill the Audit summon within the period of 4 (four)
months from the date of Summons is issued for Office Audit.

b.

Field Audit or Office Audit, which is postponed due it is followed


up with the Preliminary evidence Audit publicly and the
Preliminary evidence Audit publicly:
1) shall not be continued with the investigation because the
Taxpayer disclose the untruth of its actions, as referred to in
Article 8 clause (3), of the Law of KUP;
2) shall not be continued with the investigation but settled by
issuing the Tax Underpayment Letter, as referred to in Article
13A of the Law of KUP; or
3) shall be continued with the investigation, but its investigation
is stopped due to no prosecution made as referred to in Article
44B of the Law of KUP.

c.

Field Audit or Office Audit that is postponed due to it is followed


up with investigation as the follow up of the Preliminary evidence
Audit in enclosed manner and its investigation is stopped because
it meets the provision as referred to in Article 44B of the Law of
KUP.

d.

Re-Audit did not result any addition on the tax amount that has
been set in the previous tax assessments letter.

e.

There are a certain circumstances based on consideration of the


Director General of Tax.
Article 22

(1) Completion of Audit by making LHP, as referred to in Article 20


letter b, shall be conducted in terms of:
a. Taxpayer, its representative, proxy, employee, or adult family
member of the audited Taxpayer in connection with the Tax
Overpayment Refund Request as referred to in Article 17B of
the Law of KUP:
1) is not found within the period of 6 (six) months from the
date of the Field Audit Notification Letter is issued; or
2) does not fulfill the Audit summon within the period of 4
(four) months from the date of Summons Letter is issued for

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 17 Office Audit.
b. Taxpayer, its representative, proxy, employee, or adult family
member from the audited Taxpayer is found or fulfilled the
Audit summons, and the Audit can be completed within a
period of Audit.
c. Taxpayer, its representative, proxy, employee, or adult family
member from the audited Taxpayer is found or fulfilled the
Audit summon, and the examination of fulfillment compliance
of tax obligations cannot be completed until:
1) end of the Field Audit examination period extension as
referred to in Article 16 clause (1) or clause (3); or
2) end of the Office Audit examination period extension as
referred to in Article 17 clause (1).
d. Is Field Audit or Office Audit that a suspended due to it is
followed up with the Preliminary evidence Audit publicly and
the Preliminary evidence Audit publicly:
1) shall be stopped because the individual Taxpayer who are
under Preliminary evidence Audit publicly is passed away;
2) shall be stopped because there is not any preliminary
evidence of criminal offenses in the field of taxation;
3) shall be continued with the investigation, but its
investigation is stopped because has been fulfilled the
provisions as referred to in Article 44A of the Law of KUP; or
4) shall be continued with the investigation and the
prosecution as well as there has been a Court Verdict
concerning criminal offences in the field of taxation that
already have permanent legal force, and a copy of the Court
Verdict has been accepted by the Director General of Tax.
e. Field Audit or Office Audit that is postponed due to it is
followed with investigation as the follow up of Preliminary
evidence Audit in enclosed and such investigation:
1) shall be stopped because of the fulfilling the provisions as
referred to in Article 44A of Law of KUP; or
2) shall be continued with the prosecution and there have
been Court Verdict concerning criminal offences in the field
of taxation that already have permanent legal force, and a
copy of the Court Verdict has been accepted by the Director
General of Tax.
(2) Field Audit or Office Audit whose examination has not been
completed, as referred to in clause (1) letter c, should be

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- 18 completed by submitting the SPHP within no longer than the


period of seven (7) working days since the end of:
a. Field Audit examination period extension as referred to in
Article 16 clause (1) or clause (3); or
b. Office Audit examination period extension as referred to in
Article 17 clause (1),
and continue the Audit until the making of LHP.
Article 23
(1) Audit was stopped by making the Summary of LHP because the
Taxpayer cannot be found or does not fulfill the Audit summon, as
referred to in Article 21 letter a, re-Audit could be conducted in
the future if the Taxpayer is found.
(2) Tax payable upon the Audit against the Taxpayer who is not found
or does not fulfill the Audit summon, as referred to in Article 22
clause (1) letter a, shall be defined in ex officio.
Part Seven
SP2 and The Letter That Contains Tax Auditor Team Changes
Article 24
(1) Audit to examine the fulfillment compliance of tax obligations
shall be conducted by Tax Auditor who joined in a Tax Auditor
Team based on the SP2.
(2) SP2, as referred to in clause (1), shall be issued for one or more
Tax period in part of Fiscal Year or in the same Fiscal Year or for
one part of the Fiscal Year or Fiscal Year on one Taxpayer.
(3) In terms of the Tax Auditor team composition is changed, the
head of Audit executor unit should issue a letter containing the
Tax Auditor team changes.
(4) In terms of Tax Auditor team is assisted by the expert, as referred
to in Article 8 clause e, such expert assigned based on the
assignment letter issued by the Director General of Tax.
Part Eight
Audit Notification and Summon,
and Meeting with The Taxpayer
Article 25
(1) In terms of the conducted Audit to examine the fulfillment
compliance of tax obligations is Field Audit, the Tax Auditor shall
be Obliged to notify the Taxpayer regarding the Field Audit that
will be conducted by submitting the Field Audit Notification Letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 19 (2) In terms of the conducted Audit to examine the fulfillment


compliance of tax obligation is Office Audit, the Tax Auditor shall
be Obliged to notify the Taxpayer regarding the Office Audit which
will be performed by submitting the Summons for Office Audit.
(3) Field Audit Notification, as referred to in clause (1), or the
Summons for Office Audit, as referred to in clause (2), shall be
issued for the Tax Period, part of the Fiscal Year, or the Fiscal
Year as mentioned in SP2.
Article 26
(1) Field Audit Notification, as referred to in Article 25 clause (1),
could be submitted directly to the Taxpayer at the time of
commencement of Field Audit or delivered by fax, registered mail
or other registered courier service.
(2) In terms of the Field Audit Notification is submitted directly, as
referred to in clause (1), and the Taxpayer is not in place, the Field
Audit Notification could be submitted to:
a. representative or the taxpayers proxy, or
b. party that could represent the Taxpayer, namely:
1) employee of the Taxpayer that according to the Tax Auditor
is deemed could represent the Taxpayer, in terms of the
Audit is conducted againts corporate Taxpayer;
2) Adult family member of the Taxpayer that according to the
Tax Auditor could represent the Taxpayer, in terms of the
Audit is conducted against individual Taxpayer; or
3) party other than referred to in number 1) and 2), who could
represent the Taxpayer.
(3) In terms of the representative or taxpayers proxy or the party who
could represent the Taxpayer, as referred to in clause (2), could
not be found, Field Audit Notification shall be delivered with
registered mail or other registerd courier services and the Field
Audit Notification is deemed to have been delivered and the Field
Audits has been commenced.
(4) Summon for Office Audit, as referred to in Article 25 clause (2),
shall be submitted by fax, registered postal service or other
registered courier service.
Article 27
(1) In implementing the Audit to examine the fulfillment compliance
of tax obligation, the Tax Auditor shall be obliged to held the
meeting with the Taxpayer in accordance with the provisions as

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OF THE REPUBLIC OF INDONESIA

- 20 referred to in Article 11 letter c.


(2) Meeting, as referred to in clause (1), could also be held with the
representative or the Taxpayers proxy.
(3) In terms of the Audit conducted by Field Audits, the meeting as
referred to in clause (1) or clause (2) is conducted after the Tax
Auditor submitting the Field Audit Notification.
(4) In terms of the conducted Audit the Office Audit, the meeting as
referred to in clause (1) or clause (2) shall be held when the
Taxpayer, its representative, or the Taxpayers proxy come to fulfill
the Summon for Office Audit.
(5) After performing the meeting, as referred to in clause (1) or clause
(2), the Tax Auditor shall be obliged to make the minute of
meeting result, which is signed by the Tax Auditor and the
Taxpayer, its representative, or the taxpayers proxy.
(6) In terms of the Taxpayer, its representative, or the taxpayers
proxy refuses to sign the minute of meeting, as referred to in
clause (5), the Tax Auditor makes the note regarding such refusal
in the minute of meeting results.
(7) In terms of the Tax Auditor has signed the minute of meeting and
made the note regarding the refusal of the signing of minute, as
referred to in clause (5), the meeting as referred to in clause (1) or
clause (2) shall be considered to have been held.
Part Nine
Borrowing Document
Article 28
(1) In terms of the conducted Audit to examine the fulfillment
compliance of tax obligations is Field Audit, these following
provisions shall be applied:
a. books, records, and/ or documents, including electronically
managed data and other information that are required and
obtained/ found at which the Audit implementation take place
at the Taxpayers place, is borrowed at the moment and the
Tax Auditor makes receipt of the borrowing and the returning
of books, records, and documents.
b. in the terms of the books, records, and/ or documents,
including electronically managed data and other necessary
information has not been found or given by the Taxpayer at
the time of Audit implementation, as referred to in letter a, the
Tax Auditor makes request for borrowing books, records, and
documents that are attached to the list of books, records,

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OF THE REPUBLIC OF INDONESIA

- 21 and/ or documents that shall be obliged to be borrowed.


c. in terms to access and/ or to download the electronically
managed data is need equipment and/ or special expertise,
the Tax Auditor could ask for assistance to:
1) Taxpayer to provide manpower and/ or equipment at the
expense of the taxpayer;or
2) one or more persons who have a particular expertise, both
derived from the Directorate General of Tax as well as from
outside of the Directorate General of Tax.
(2) In terms of the conducted Audit to examine the fulfillment
compliance of tax obligations is Office Audits, these following
provisions shall be applied:
a. list of books, records, and/ or documents, including
electronically managed data and other information that are
required by the Tax Auditor, should be attached to the
Summons For Audit Office.
b. books, records, and/ or documents, including electronically
managed data and other information, as referred to in letter a,
shall be obliged to be borrowed at which the Taxpayer fulfills
the Summon for Office Audit and Tax Auditor makes the
receipt of the borrowing and the returning of books, records,
and documents .
c. in terms of the books, records, and/ or documents, including
electronically managed data and other information that is
required, is not listed in the appendix of the Summons For
Office Audit, as referred to in letter a, the Tax Auditor makes a
request letter of borrowing books, records, and documents.
(3) Books, records, and/ or documents, including electronically
managed data and other information, as referred to in clause (1)
letter b or clause (2) letter c, shall be obliged to be submitted to
the Tax Auditor within maximum period of 1 (one) month since
the request letter of borrowing books, records, and documents is
delivered.
(4) Each submission of books, records, and/ or documents, including
electronically managed data and other information from the
Taxpayer, the Tax Auditor makes receipt of the borrowing and the
returning of books, records, and documents.
(5) In terms of the borrowed books, records, and/ or documents in a
form of a copy and/ or in the form of electronically managed data,
the audited Taxpayer should make a statement that the copy
and/ or the electronically managed data that are borrowed to the

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 22 Tax Auditor shall be in accordance with the original.


(6) In terms of the books, records, and/ or documents, including
electronically managed data and other information that is
borrowed has not been fulfilled and the period of 1 (one) month,
as referred to in clause (3), has not exceeded, the Tax Auditor
could deliver written warning for no longer than 2 (two) times,
namely:
a. first warning letter shall be after 2 (two) weeks since the date
of submission of the request letter of borrowing books,
records, and documents as referred to in clause (1) letter b or
clause (2) letter c;
b. second warning letter shall be after three (3) weeks from the
date of submission of the request letter of borrowing books,
records, and documents as referred to in clause (1) letter b or
clause (2) letter c.
(7) Any warning letter, as referred to in clause (6), should be attached
with the list of books, records, and documents that have not been
borrowed for the Audit.
Article 29
(1) In terms of the books, records, and/ or documents, including
electronically managed data and other information that is
requested by the Tax Auditor is not owned or under the control of
the Taxpayer, the Taxpayer should make the statement letter
certifies that the books, records, and/ or documents, including
electronically managed data and other information requested by
the Tax Auditor is not owned or under control the the Taxpayer.
(2) In terms of the books, records, and/ or documents, including
electronically managed data and other information that is
required to be protected its confidentiality, the Taxpayer could
apply the request in order to Audit implementation could be
carried out at the Taxpayers place by providing a special room.
Article 30
(1) In the event that within the period of 1 (one) month, as referred to
in Article 28 clause (3), is exceeded and the Taxpayer does not or
does not fully borrow the books, records, and/ or documents,
including electronically managed data and other information
which are requested, the Tax Auditor should make the minute of
unfulfilling the requests for borrowing books, records, and
documents attached with the list detailed of books, records, and
documents that shall be obliged to be borrowed but not yet
delivered by the Taxpayer.

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OF THE REPUBLIC OF INDONESIA

- 23 (2) In the event that the Taxpayer has borrowed all books, records,
and/ or documents, including electronically managed data and
other information which is requested, the Tax Auditor should
make the minute of fulfilling all borrowing books, records and
documents.
Article 31
(1) In the event that the Taxpayer does not or does not fully borrow
the books, records, and/ or documents, including electronically
managed data and other information that is requested based on
the minute of unfulfilling the request for borrowing books, records
and documents, as referred to in Article 30 clause (1 ), the Tax
Auditor should determine whether it could or could not carry out
the examination for calculating the amount of taxable income
based on the adequate competent evidence in accordance with the
Audit implementation standards.
(2) In the event that the conducted Audit againts individual Taxpayer
who run the business or a self-employed or corporate Taxpayer
and the Tax Auditor could not carry out the examination for
calculating the amount of taxable income, as referred to in clause
(1), such taxable income could be calculated in ex officio in
accordance with the provisions of the legislation of taxation.
(3) In terms of the Taxable Income is not calculated in ex officio, the
Tax Auditor could borrow additional books, records, and/ or
documents and other information in addition to that has been
already borrowed.
Part Ten
Sealing
Article 32
(1) Tax Auditor shall be authorized to conduct the sealing to obtain or
to secure books, records, and/ or documents, including
electronically managed data, and other objects that may give clues
regarding the business activities or self-employed Taxpayers who
is audited in order not to be moved, removed, destroyed, changed,
defaced, switched, or falsified.
(2) Sealing, as referred to in clause (1), shall be conducted, in the
event when the Field Audits implementation:
a. Taxpayers, representative, or the audited taxpayers proxy
does not give an opportunity to the Tax Auditor to enter place
or space as well to examine tangible goods and/ or intangible
goods, that are allegedly or reasonably suspected to be utilized
for storing books or records, and/ or documents, including the

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OF THE REPUBLIC OF INDONESIA

- 24 data processing result from the accounting that managed


electronically or in on-line application program that could
provide clues regarding the business activities or selfemployed Taxpayer;
b. Taxpayer, representative, or the audited taxpayers proxy is
refused to give assistance for the examination smoothness,
which is including does not giving opportunity to the Tax
Auditor accessing maintained electronically data or opening
tangible and/ or intangible good;
c. Taxpayer, representative, or the audited Taxpayers proxy is
not in place and no employee or an adult family member of the
Taxpayer who has the authority to act as the party who
represents the Taxpayers, so it is necessary to perform a
security measures before the Audit is postponed; or
d. Taxpayer, representative, or the audited Taxpayers proxy is
not in place and the employee or an adult family member from
the Taxpayer who has the authority to act as the party who
represents the Taxpayer refuses to provide assistance for the
smoothness of Audit.
Article 33
(1) Sealing, as referred to in Article 32 clause (1), shall be conducted
using the seal sign.
(2) Sealing shall be conducted by the Tax Auditor and witnessed by at
least two (2) adult persons other than the Tax Auditor team
members.
(3) In conducting the Sealing, the Tax Auditor shall be obliged to
make the minute of sealing.
(4) Minute of Sealing, as referred to in clause (3), shall be made and
signed by the Tax Auditor and witnessed by at least two (2) adult
persons other than the Tax Auditor team members.
(5) Minute of Sealing, as referred to in clause (3), shall be made in 2
(two) copies and the second copy shall be handed to the Taxpayer,
it representative, proxy, employee, or adult family member of the
audited taxpayer.
(6) In the event that the witnesses, as referred to in clause (2), refuses
to sign the minute of Sealing, the Tax Auditor makes note of such
refusal mentioned in the minute of Sealing.
(7) In conducting the Sealing, the Tax Auditor could request for the
assistance from the Indonesian National Police and/ or the
regional government.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 25 Article 34
(1) The opening of the Seal shall be conducted in the event that:
a. Taxpayer, its representative, proxy, or those who could
represent the Taxpayers, as referred to in Article 26 clause (2)
letter b, has given the permission to the Tax Auditor to open or
enter the place or room, sealed tangible or intangible good,
and/ or to give an assistance for the smoothness of Audit;
b. based on the consideration of the Tax Auditor, the Sealing is
not required anymore, and/ or
c. there is request from the investigator who conduct criminal
investigations.
(2) The Opening of the seal should be carried out by the Tax Auditor
and witnessed by at least two (2) adult persons other than the Tax
Auditor team members.
(3) In certain circumstances, opening of the seals could be assisted
by the Indonesia National Police and or the regional government.
(4) In the event that the seal sign that is utilized to perform the
Sealing is damaged or missing, the Tax Auditor should make a
minute of damage or loss and reports it to the Indonesia National
Police.
(5) In opening the seal, the Tax Auditor makes the minute of seal
opening, which is signed by the Tax Auditor and the witnessed as
referred to in clause (2).
(6) In the event that the witnesses ,as referred to in clause (7), refuses
to sign the minute of seal opening, the Tax Auditor make note of
the refusal in the minute of the seal opening.
(7) Minute of seal opening shall be made in 2 (two) copies and the
second copy shall be handed to the Taxpayer, its representative,
proxy, employee, or an adult family member of the Taxpayer.
Article 35
(1) In the event that within 7 (seven) days after the date of Sealing or
other the period by considering the Sealing purposes, the
Taxpayer, its representative, or the Taxpayers proxy still does not
give permission to the Tax Auditor to open or enter the sealed
place or space, tangible or intangible goods, and/ or does not
provide assistance for the smoothness of Audit, the Taxpayer shall
be considered refusing the Audit.
(2) In case the taxpayer is considered refusing the Audit, as referred
to in clause (1), the Taxpayers, its representative, or the

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OF THE REPUBLIC OF INDONESIA

- 26 Taxpayers proxy shall be obliged to sign the refusal statement of


the Audit.
(3) In case the Taxpayer, its representative, or the Taxpayers proxy
refuses to sign the refusal statement, as referred to in clause (2),
the Tax Auditor makes and signs the minute regarding such
refusal.
Part Eleven
Refusal of Audit
Article 36
(1) In case the Taxpayer, its representative, or the Taxpayers proxy
who is under Field Audits to examine the fulfillment compliance of
tax obligations certifies to refuse conducting the Examination
including refusing to receive the Field Audit Notification Letter,
the Taxpayer, its representative, or the Taxpayers proxy should
sign the refusal statement of Audit.
(2) In case the Taxpayer, its representative, or the Taxpayers proxy
refuses to sign the refusal statement of the Audit, as referred to in
clause (1), Tax Auditor makes the minute refusal of Audit that is
signed by the Tax Auditor team.
(3) In case the Taxpayer, its representative, or the Taxpayers proxy is
not in place, then:
a. Audit could remain be conducted as long as there are
employee or an adult family member of the Taxpayer who
could and has the authority to represent the Taxpayer, it shall
be limited to the metters that are in its authority; or
b. Audit shall be postponed to be continued in the next
opportunity.
(4) For the purposes of the Audit security measures, prior
postponement, as referred to in clause (3) letter b, the Tax Auditor
could conduct a Sealing as referred to in Article 32 clause (1).
(5) In the event after the Sealing within the period, as referred to in
Article 35 clause (1), the Taxpayer, its representative, or the
Taxpayers proxy remain not in place and/ or does not give a
permission to the Tax Auditor to open or enter the place or space,
tangible/ intangible goods, and/ or does not provide assistance
for the smoothness of Audit, the Tax Auditor asks to the employee
or an adult family member from the taxpayer to assist the
smoothness of Audit.
(6) In the event that the employee or the adult family member from
the Taxpayer, as referred to in clause (5), refuses to assist the
smoothness of the Audit, the Tax Auditor askes the employee or

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- 27 the adult family member from the Taxpayer to sign the letter of
refusal to assist the smoothness of the Audit.
(7) In the event that the employee or the adult family member from
the Taxpayer refuses to sign the letter of the refusal to assist the
smoothness of the Audit, as referred to in clause (6), the Tax
Auditor makes an minute of refusal to assist the smoothness of
the Audit of which is signed by the Tax Auditor team.
Article 37
(1) In terms of the Taxpayer, its representative, or the Taxpayers
proxy conducts the Office Audit to examine the fulfillment
compliance of tax obligations in fulfilling the Summons for Office
Audit but refuses to perform the Audit, the Taxpayer, its
representative, or the Taxpayers proxy should sign the statement
letter of the Audit refusal.
(2) In terms of the Taxpayer, its representative, or the Taxpayers
proxy refuses to sign the statement letter of the Audit refusal, as
referred to in clause (1), the Tax Auditor shall make an minute of
the Audit refusal of which is signed by the Tax Auditor team.
(3) In the event that in the maximum period of 1 (one) month from
the Summons for Office Audit is delivered to the Taxpayer and the
summons is not returned by postal service or other courier service
and the Taxpayer doesnt fulfill the Office Audit summon, the Tax
Auditor shall make the minute of the unfulfilling of the Audit
summon by the Taxpayer that is signed by the Tax Auditor team.
Article 38
Tax Auditor, based on:
a.

Audit refusal statement letter, as referred to in Article 35 clause


(2), Article 36 clause (1), or Article 37 clause (1);

b.

minute of the Audit refusal as referred to in Article 35 clause (3),


Article 36 clause (2), or Article 37 clause (2);

c.

minute of the Audit summon non-fulfilled, as referred to in Article


37 clause (3);

d.

refusal letter to assist the smoothness of Audit as referred to in


Article 36 clause (6); or

e.

minute of the refusal to assist the smoothness of Audit as referred


to in Article 36 clause (7);

could conduct the tax assessment in ex officio or proposed the


Preliminary Evidence Audit.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 28 Part Twelve
Taxpayer Explanation and
Request for Information to Third Party
Article 39
(1) To obtain a more detailed explanation, the Tax Auditor through
the head of the Audit executor unit could call the Taxpayer, its
representative, the Taxpayers proxy, employee or adult family
member of the Taxpayer through the submission of summon.
(2) In terms of the conducted Audit is Field Audit, more detailed
explanation, as referred to in clause (1) could be conducted at the
time of the Audit implementation is conducted on the Taxpayers
place.
(3) Explanation, as referred to in clause (1) or clause (2), which is
given to the Tax Auditor, shall be included in the minute
regarding the explanation given by the Taxpayer that is signed by
the Tax Auditor team and the Taxpayer, its representative, the
Taxpayers proxy, employee or adult family member of the
taxpayer.
(4) In terms of the Taxpayer, its representative, the Taxpayers proxy,
employee or adult family member from the taxpayer refuses to
sign the minute, as referred to in clause (3), the Tax Auditor
makes a note of the refusal in the acknowledgement in question.
Article 40
Tax Auditor through the head of the Audit executor unit could request
information and/ or evidence to third party, as referred to in Article 35
of the Law of KUP in writing in accordance with the Regulation of the
Minister of Finance of which sets out the procedures for information
request to third party.
Part Thirteen
Notification of Tax Audit Finding and
Audit Result Final Discussion
Article 41
(1) Audit results to examine the fulfillment compliance of tax
obligations should be notified to the Taxpayer through the delivery
of SPHP of which is attached with the list of Audit findings.
(2) SPHP and the list of Audit findings, as referred to in clause (1),
could be delivered directly by the Tax Auditor or through fax.
(3) In terms of the SPHP is delivered directly and Taxpayer,

its

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OF THE REPUBLIC OF INDONESIA

- 29 representative, or the Taxpayers proxy refuses to accept the


SPHP, Taxpayer, its representative, or the Taxpayers shall be
obliged sign refusal letter of the SPHP acceptance.
(4) In terms of the Taxpayer, its representative, or the Taxpayers
proxy refuses to sign the refusal letter of the SPHP acceptance, as
referred to in clause (3), the Tax Auditor makes minute refusal of
the SPHP acceptance of which is signed by the Tax Auditor team.
Article 42
(1) Taxpayer shall be obliged to give the written response against
SPHP and list of Audit findings, as referred to in Article 41 clause
(1), in the form of:
a. Audit results approval statement sheet in the event that
Taxpayer approves all Audit results; or
b. Refutation letter, in the event that Taxpayer doesnt agree on a
part or overall results of the Audit.
(2) Written response, as referred to in clause (1), should be submitted
within the period of seven (7) working days since the date of SPHP
is received by Taxpayer.
(3) Taxpayers could extend the period of the written response
submission, as referred to in clause (2,) for maximum period of 3
(three) working days since the period as referred to in clause (2)
ends.
(4) To extend the response submission period, as referred to in clause
(3), the Taxpayer should submit a written notice before the period
as referred to in clause (2) ends.
(5) Written response, as referred to in clause (1), and written notice
as referred to in clause (4), shall be submitted by the Taxpayer
directly or through fax.
(6) In case the Taxpayer fails to submit written response againts the
SPHP, Tax Auditor makes the minute regarding the failure to
submit written response against SPHP of which is signed by the
Tax Auditor team.
Article 43
(1) In order to implement final discussion of the Audit result that is
listed in SPHP and list of Audit findings, as referred to in Article
41 clause (1), to the Taxpayer should be given the right to attend
in the Audit Result Final Discussion.
(2) Rights to attend, as referred to in clause (1), shall be given
through written invitation delivered to the Taxpayer by mentioning
the day and date of the implementation of the Audit Results Final

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- 30 Discussion.
(3) Invitation, as referred to in clause (2), should be delivered to the
Taxpayer within the maximum period of 3 (three) working days
commencing from:
a. acceptance of the written response against SPHP from the
Taxpayer is in accordance with the period as referred to in
Article 42 clause (2) or clause (3); or
b. Expiration period, as referred to in Article 42 clause (3), in the
event that Taxpayer fails to submit written response against
the SPHP.
(4) Invitation, as referred to in clause (2), could be submitted by the
Tax Auditor in directly or through facsimile.
Article 44
(1) In the event that the Taxpayer, its representative, or the
Taxpayers proxy:
a. submits the Audit results approval statement sheet, as
referred to in Article 42 clause (1) letter a within the period as
referred to in Article 42 clause (2) or clause (3);and
b. attends in the Audit Results Final Discussion in accordance
with the day and date specified in the written invitation as
referred to in Article 43 clause (2),
Tax Auditors makes treatise of the discussion based on the Audit
results approval statement sheet and makes the minute of Audit
Results Final Discussion attached with the treatise of the final
discussion, which is signed by Tax Auditor team and Taxpayer, its
representative, or the Taxpayers proxy.
(2) In the event that Taxpayer, its representative, or the Taxpayers
proxy:
a. submits the Audit results approval statement sheet, as
referred to in Article 42 clause (1) letter a, within the period as
referred to in Article 42 clause (2) or clause (3); and
b. does not attending the Audit Result Final Discussion in
accordance with the day and date specified in the written
invitation as referred to in Article 43 clause (2),
Tax Auditors makes treatise of the discussion based on the Audit
results approval statement sheet, minute of absence of the
Taxpayer in the Audit Results Final Discussion, and minute of
Audit Results Final Discussion of which is attached with the
treatise of final discussion, which is signed by the Tax Auditor

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 31 team.
(3) In the event that Taxpayer, its representative, or the Taxpayers
proxy:
a. submits the refutation letter of Audit results contents as
referred to in Article 42 clause (1) letter b, within the period as
referred to in Article 42 clause (2) or clause (3); and
b. attends the Audit Results Final Discussion in accordance with
the invitation as referred to in Article 43 clause (2),
Tax Auditors should implement Audit Results Final Discussion
with the Taxpayer based on the refutation letter and mention the
results of the discussion in the treatise of the discussion, which is
signed by the Tax Auditor team and the Taxpayer, its
representative, or the Taxpayers proxy.
(4) In the event that Taxpayer, its representative, or the Taxpayers
proxy:
a. submits refutation letter, as referred to in Article 42 clause (1)
letter b, within the period as referred to in Article 42 clause (2)
or clause (3); and
b. does not attend Audit Results Final Discussion in accordance
with the day and date specified in the invitation as referred to
in Article 43 clause (2),
Tax Auditor makes treatise of discussion based on the refutation
letter, minute of Taxpayers absence in the Audit Results Final
Discussion, and minute of the Audit Results Final Discussion that
is attached with the treatise of final discussion, which is signed
by the Tax Auditor team.
(5) In the event that Taxpayer, its representative, or the Taxpayers
proxy:
a. does not submit the written response against SPHP, as
referred to in Article 42 clause (1), within the period as
referred to in Article 42 clause (2) or clause (3); and
b. attends Audit Result Final Discussion in accordance with the
invitation as referred to in Article 43 clause (2),
Tax Auditors remains implementing the Audit Results Final
Discussion with the Taxpayer and mentions the results of the
discussion in treatise of discussion, which is signed by the Tax
Auditor team and the Taxpayer, its representative, or the
Taxpayers proxy.
(6) In the event that Taxpayer, its representative, or the Taxpayers
proxy:

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 32 a. does not submit the written response against SPHP, as


referred to in Article 42 clause (1), within the period as
referred to in Article 42 clause (2) or clause (3); and
b. does not attend the Audit Results Final Discussion in
accordance with the day and date specified in the invitation as
referred to in Article 43 clause (2),
Tax Auditor makes treatise of discussion based on SPHP, as
referred to in Article 41 clause (1), minute of the Taxpayers
absence in the Audit Results Final Discussion, and minute of the
Audit Results Final Discussion that is attached with treatise of
final discussion, which is signed by the Tax Auditor team
Article 45
(1) In the event that there is any Audit results have not been agreed
in the treatise of the discussion, as referred to in Article 44 clause
(3) or clause (5), and the Taxpayer proposes the request for a
discussion with the Audit Quality Assurance Team, minute of the
Audit Results Final Discussion that is attached with treatise of
final discussion is made after the discussion with the Audit
Quality Assurance Team is implemented.
(2) In the event that Taxpayer does not propose the request for a
discussion with the Audit Quality Assurance Team, minute of
Audit Results Final Discussion that is attached with treatise of the
final discussion is made based on treatise of the discussion as
referred to in Article 44 clause (3) or clause (5).
(3) In the event that Taxpayer, its representative, or the Taxpayers
proxy refuses to sign treatise of discussion, as referred to in
Article 44 clause (3) or clause (5), and/ or the minute of Audit
Results Final Discussion that is attached with treatise of final
discussion, as referred to in clause (2), Tax Auditor makes a note
regarding such refusal.
Article 46
(1) In the event that Taxpayer does not present in the Audit Result
Final Discussion on the day and date according to the invitation
as referred to in Article 43 clause (2), the Audit Result Final
Discussion shall be deemed have been performed.
(2) In the event that Audit Result Final Discussion is deemed have
been performed, as referred to in clause (1), the minute of Audit
Results Final Discussion that is attached with treatise of final
discussion, which is signed by Tax Auditor team.
Article 47

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 33 (1) In the event that Taxpayer proposes the request for discussion
with the Audit Quality Assurance Team, as referred to in Article 45
clause (1), Taxpayer proposes the request letter addressed to:
a. Head of Regional Office of the Directorate General of Tax in the
event that the Audit is conducted by Tax Auditor at the Tax
Office or at Regional Office of the Directorate General of Tax;
or
b. Director of Audit and Collection, in the event that Audit is
conducted by Tax Auditor at the Directorate of Audit and
Collection.
(2) Request for discussion with the Audit Quality Assurance Team, as
referred to in clause (1) could be performed if:
a. treatise of discussion, as referred to in Article 44 clause (3) or
clause (5) has been signed by Tax Auditor team and the
Taxpayer, its representatives, or the Taxpayers proxy; and
b. minute of Audit Result Final Discussion, as referred to in
Article 45 clause (2), has not been signed by Tax Auditor team
and the Taxpayer, its representative, or the Taxpayers proxy.
(3) Request letter for discussion with the Audit Quality Assurance
Team, as referred to in clause (1) ,should be delivered directly or
through facsimile within the maximum period of 3 (three) working
days since the signing of treatise of discussion, as referred to in
Article 44 clause (3) or clause (5 ) and forwarded to head of the
Audit Executor unit.
Article 48
(1) Composition of Audit Quality Assurance Team consists of 1 (one)
Chairman, 1 (one) secretary, and 3 (three) members.
(2) Audit Quality Assurance Team, as referred to in clause (1), shall
be established by Director of Audit and Collection or by Head of
Regional Office of the Directorate General of Tax on behalf of the
Director General of Tax.
Article 49
Audit Quality Assurance Team, as referred to in Article 48 clause (1),
assigns to:
a.

discuss the disagreement between Taxpayer and Tax Auditor at


the time of the Audit Results Final Discussion;

b.

make conclusion and decision upon the disagreement between the


Taxpayer and Tax Auditor; and

c.

make the treatise of Audit Quality Assurance Team of which

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 34 contains conclusion and decision of discussion results, as referred


to in clause b and with a binding nature.
Article 50
(1) Based on request letter, as referred to in Article 47 clause (3), the
Audit Quality Assurance Team should submit invitation to the
Taxpayer and Tax Auditor to carry out the discussion upon the
Audit result of which has not been agreed in the treatise of
discussion as referred to in Article 44 clause (3) or clause (5).
(2) Invitation, as referred to in clause (1,) could be delivered directly
or through facsimile.
Article 51
(1) Discussion with the Audit Quality Assurance Team shall be
conducted by the Audit Quality Assurance Team, Tax Auditor
team, and Taxpayer, its representative, or the Taxpayers proxy.
(2) In the event that Taxpayer does not attend in discussion with the
Audit Quality Assurance team in accordance with day and date
mentioned in the invitation, as referred to in Article 50 clause (1),
discussion with the Audit Quality Assurance Team shall remain be
performed by Audit Quality Assurance Team and Tax Auditor
team.
Article 52
Implementation of Audit Results Final Discussion between the
Taxpayer with the Tax Auditor, as referred to in Article 44 clause (3) or
clause (5), and implementation of discussion of the Audit Quality
Assurance Team, as referred to in Article 51, should consider the
period of Audit Results Final Discussion and the report as referred to
in Article 15 clause (4).
Article 53
(1) Result of discussion with the Audit Quality Assurance Team shall
be mentioned in treatise of the Audit Quality Assurance Team.
(2) In the event that the Taxpayer, its representative, or the
Taxpayers proxy attends the discussion with the Audit Quality
Assurance Team, the treatise of Audit Quality Assurance Team, as
referred to in clause (1), shall be signed by the Audit Quality
Assurance Team, Tax Auditor team and the Taxpayer, its
representative, or the taxpayers proxy.
(3) In the event that the Taxpayer, its representative,
taxpayers proxy attends the discussion with the Audit
Assurance Team, but the Taxpayer, its representative,
Taxpayers proxy refuses to sign the treatise of Audit

or the
Quality
or the
Quality

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 35 Assurance Team, as referred to in clause (1), the Audit Quality


Assurance Team should make the note of refusal of such refusal
in the treatise of Audit Quality Assurance Team.
(4) In the event that the Taxpayer, its representative, or the
Taxpayers proxy does not attend the discussion with the Audit
Quality Assurance Team in accordance with day and date
mentioned in the invitation, as referred to in Article 50 clause (1),
Audit Quality Assurance Team makes:
a. minute of Taxpayer absence in the discussions with the Audit
Quality Assurance Team of which is signed by the Audit
Quality Assurance Team; and
b. treatise of Audit Quality Assurance Team, as referred to in
clause (1),
of which is signed by Audit Quality Assurance Team and the Tax
Auditor team.
(5) In the event that the Taxpayer does not attend the discussion at
day and date in accordance with the invitation, as referred to in
Article 50 clause (1), discussion with the Audit Quality Assurance
Team shall be deemed have been performed.
Article 54
Treatise of the Discussion, as referred to in Article 44 clause (3) or
clause (5), and treatise of the Audit Quality Assurance Team, as
referred to in Article 53 clause (1), shall be utilized by the Tax Auditor
as a basis for making the minute of Audit Results Final Discussion of
which is attached by the treatise of final discussion results.
Article 55
(1) In order to sign the minute of Audit Results Final Discussion, as
referred to in Article 54, Tax Audit through the head of Audit
executor unit summons Taxpayer by sending summon to sign the
acknowledgement of the Audit Results Final Discussion.
(2) Summon, as referred to in clause (1), could be delivered directly or
through facsimile.
(3) In the event such summon is delivered directly and the Taxpayer,
its representative, or the Taxpayers proxy refuses to accept such
summons; Taxpayer, its representative, or the Taxpayers proxy
should sign refusal letter to accept the summon to sign the
minute of Audit Results Final Discussion.
(4) In the even the Taxpayer, its representative, or the Taxpayers
proxy refuses to sign the refusal letter, as referred to in clause (3),
Tax Auditor makes an acknowledgement of the refusal to accept

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 36 the summons to sign the minute of Audit Results Final Discussion


of which is signed by the Tax Auditor team.
Article 56
(1) Taxpayer should fulfill the summon, as referred to in Article 55
clause (1), within the period of three (3) working days after the
summon to sign the minute of the Audit Result Final Discussion
is received by Taxpayer.
(2) In the event that the Taxpayer, its representative, or the
Taxpayers proxy fulfill the summon, as referred to in Article 55
clause (1), but refuses to sign the minute of Audit Results Final
Discussion, Tax Auditor makes the note regarding the refusal of
signing of the minute of Audit Results Final Discussion.
(3) In the event that the Taxpayer does not fulfill the summon, as
referred to in Article 55 clause (1), Tax Auditor makes the note on
the minute of Audit Results Final Discussion regarding the
unfulfilled of the summon.
Article 57
In the event that against Taxpayer is performed in ex officio
assessment, as referred to in Article 31 clause (2) or Article 38, the
books, records, and/ or documents, including electronically managed
data and other information of which could be considered by the Tax
Auditor in Audit Results Final Discussion shall be limited to:
a.

gross income for the calculation of income in ex officio; and

b.

tax credit as a reduction of Income Tax.


Part Fourteen
Audit Results Reporting and
Documents Returning
Article 58

(1) LHP shall be prepared by KKP, as referred to in Article 10.


(2) Treatise of the discussion, treatise of Audit Quality Assurance
Team, and/ or minute of Audit Results Final Discussion,
constitutes an integral part of LHP as referred to in clause (1).
(3) LHP, as referred to in clause (1), shall be utilized by Tax Auditor
as the basis for making the tax calculation note.
(4) Tax calculation note, as referred to in clause (3), shall be utilized
as the basis for the issuance of tax assessments letter or Tax Bill.
(5) Tax payable in the tax assessment letter, as referred to in clause
(4), shall be calculated in accordance with Audit Results Final

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 37 Discussion, unless:
a. in the event that the Taxpayer does not attend the Audit
Results Final Discussion but delivres Audit result approval
statement sheet, as referred to in Article 44 clause (2), tax
payable shall be calculated in accordance with the Audit
results approval statement sheet;
b. in the event that the Taxpayer does not attend the Audit
Results Final Discussion but delivers the refutation letter, as
referred to in Article 44 clause (5), the tax payable shall be
calculated based on SPHP with the amount that is not
approved in accordance with the Taxpayers refutation letter;
c. in the event that the Taxpayer does not attend the Audit
Results Final Discussion and does not deliver the written
response on SPHP, as referred to in Article 44 clause (6), the
tax payable shall be calculated based on SPHP, as referred to
in Article 41 clause (1), and Taxpayer shall be deemed
approving the Audit results .
Article 59
Books, records, and documents that are borrowed should be returned
to the Taxpayer using receipt of borrowing and returning of books,
records and documents within no longer than 7 (seven) working days
since the date of LHP.
Part Fifteen
Audit Result Cancellation
Article 60
(1) Tax assessment letter from the Audit result of which is conducted
without:
a. SPHP submission; or
b. Audit Results Final Discussion,
could be canceled in ex officio or based on Tax Payer request by
Director General of Tax, as referred to in Article 36 clause (1)
letter d of Law of KUP.
(2) In the event that the cancellation is performed, as referred to in
clause (1), Audit process should be continued by implementing
SPHP submission procedures and/ or Audit Results Final
Discussion.
(3) SPHP submission procedures and/ or the implementation of the
Audit Results Final Discussion, as referred to in clause (2), should
be conducted in accordance with the provisions as set out in this

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 38 Ministerial Regulation.
(4) In the event that the Audit that is continued, as referred to in
clause (2), is related to tax overpayment refund request, as
referred to in Article 17B Clause (1), of the Law of KUP, Audit shall
be followed by the issuance of:
a. tax assessment letter in accordance with the Audit Result
Final Discussion if the period of 12 (twelve) months, as
referred to in Article 17B Clause (1), of the Lw of KUP has not
been reached;or
b. Tax Overpayment Assessment Letter in accordance with the
Tax Return if the period of 12 (twelve) months, as referred to
in Article 17B Clause (1), of the Law of KUP Law is exceeded.
(5) In terms of the membership composition of the Tax Auditor team
to continue the Audit, as referred to in clause (2), is different with
the membership composition of the previous Tax Auditor team,
Audit shall be conducted after the issuance of letter that contains
Tax Auditor team changes.
Part Sixteen
Disclosure of the Untruth of Filling of Tax Return
During Audit
Article 61
(1) Taxpayer could disclose in a written separate report regarding on
the untruth in filling of Tax return that has been delivered in
accordance with the actual situation, as referred to in Article 8
clause (4) of the Law of KUP and Article 8 of the Government
Regulation Number 74 Year 2011, as long as the Tax Auditor has
not been delivered SPHP.
(2) Disclosure of the untruth in the filling of Tax return, as referred to
in clause (1), should be delivered to Tax Office in which the
Taxpayer is registered.
(3) Written Separate report as referred to in clause (1), shall be signed
by the Taxpayer, its representative, or the Taxpayers proxy and
shall be attached with:
a. tax underpayment calculation in accordance with the actual
situation in the form of Tax return;
b. Tax Payment Slip for the underpayment taxes, and
c. Tax Payment Slip for the payment of administrative sanction
in the form of the hike of 50% (fifty percent).
(4) In the event that the disclosure of untruth in the separate report,
as referred to in clause (1), does not result a tax underpayment,

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 39 then such disclosure is not necessarily to be attached with the


Tax Payment Slip.
Article 62
(1) To prove the untruth disclosure in a separate report ,as referred to
in Article 61 clause (1), Audit shall remain be continued and for
the Audit results, a tax assessment shall be issued by considering
the separate report and calculating the principal tax that have
been paid.
(2) In the event that the Audit result, as referred to in clause (1),
proves that the disclosure of untruth filling of Tax Return by the
Taxpayer is not in accordance with the actual situation, the tax
assessment letter shall be issued in accordance with the actual
situation.
(3) In the event that the Audit result, as referred to in clause
proves that the disclosure of untruth filling of Tax Return by
Taxpayer is in accordance with the actual situation, the
assessment letter shall be issued in accordance with
disclosure of the Taxpayer.

(1),
the
tax
the

(4) Tax Payment Slip, as referred to in Article 61 clause (3) letter b,


shall be calculated as tax credit in the tax assessment letter of
which is issued based on the Audit result as referred to in clause
(1), clause (2), and clause (3).
(5) Tax Payment Slip, as referred to in Article 61 clause (3) letter c,
constitutes a proof of payment of administrative sanction in the
form of the hike of 50% (fifty percent) related to the disclosure
untruth of the filling of Tax Return.
(6) Tax assessment letter, as referred to in clause (2), shall be added
with the administrative sanction in accordance with Article 13 of
the Law of KUP.
(7) In terms of the Disclosure of untruth in filling of Tax Return, as
referred to in Article 61 clause (1,) is conducted for the Periodic
Income Tax Return, Input Tax on Taxable Goods or Taxable
services of which is not reported in the Periodic Income Tax
Return could not be calculated as tax credit, as set forth in Article
9, clause (8) letter i of the Law of Value Added Tax Year 1984 and
its amendment.
Part Seventeenth
Proposal of the Preliminary Evidence Audit and
Audit Suspension
Article 63

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 40 (1) Audit to examine the fulfillment compliance of tax obligations


could be proposed Preliminary Evidence Audit openly if:
a. during the implementation of Audit, indications of criminal
offenses in the field of taxation is found; or
b. Taxpayer refuses to be performed Audit, as referred to in
Article 36 or Article 37, and against such Taxpayer shall not
performed the calculation of taxable income in ex officio.
(2) In the event tha the conducted Audit is Audit against tax
overpayment refund request, as referred to in Article 17B of Law
of KUP, the proposals of open Preliminary Evidence Audit should
regard to the settlement period of such tax overpayment refund
request.
Article 64
(1) In the event that proposal of the open preliminary Evidence Audit,
as referred to in Article 63 clause (1), is approved by the
authorized official, the implementation of Audit shall be
suspended by making a progress report of Audit until:
a. open Preliminary Evidence Audit shall be resolved because the
Taxpayer discloses the act of untruth, as referred to in Article
8 clause (3) of the Law of KUP;
b. open Preliminary Evidence Audit shall be resolved with the
issuance of Tax Underpayment Assessment Letter as referred
to in Article 13A of Law of KUP;
c. open Preliminary Evidence Audit shall be terminated because
the Taxpayer who is under open Initial Evidence Audit is
passed away;
d. open Preliminary Evidence Audit shall be terminated because
there is not any preliminary evidence of criminal offenses in
the field of taxation is found;
e. Investigation shall be terminated in accordance with the
provisions of Article 44A of the Law of KUP or Article 44B of
the Law of KUP; or
f.

Court decision on criminal action in the field of taxation has


permanent legal force, and copy of the court's decision has
been received by the Director General of Tax.

(2) Audit Suspension, as referred to in clause (1), should be notified


in written to the Taxpayer.
(3) Written notice, as referred to in clause (2), should be delivered
concurrently with the delivery of the open Preliminary Evidence
Audit notification letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 41 (4) Books, records, and documents of which are related to the


suspended Audit, as referred to in clause (1), shall be delivered to
the Preliminary Evidence Auditor by making the minute that is
signed by the Tax Auditor and the Initial Evidence Auditor.
(5) Copy of the Minute as referred to in clause (4), shall be delivered
to Taxpayer.
Article 65
(1) The suspended Audit, as referred to in Article 64 clause (1), shall
be continued in accordance with the applicable provisions, if:
a. open Preliminary Evidence Audit is terminated because the
Taxpayer who is under open Preliminary Evidence Audit is
passed away;
b. open Preliminary Evidence Audit is terminated because there
is not any preliminary evidence of criminal offenses in the field
of taxation is found;
c. open Preliminary Evidence Audit shall be continued with the
investigation, but the investigation is terminated because it
has fulfilled the provisions, as referred to in Article 44A of the
Law of KUP; or
d. open Preliminary Evidence Audit shall be continued with the
investigation and prosecution and there have been a court
decisions regarding criminal offenses in the field of taxation
that already have permanent legal force, and the copy of the
court's decision has been received by the Director General of
Taxation.
(2) The suspended Audit, as referred to in Article 64 clause (1), shall
be terminated by making Summary of LHP, as referred to in
Article 21 letter b, if:
a. open Preliminary Evidence Audit shall be resolved because the
Taxpayer discloses its untruth act, as referred to in Article 8
clause (3) of the Law of KUP;
b. open Preliminary Evidence Audit shall not be continued with
the investigation but I shall be resolved by issuing Tax
Underpayment Assessment Letter as referred to in Article 13A
of the Law of KUP; or
c. open Preliminary Evidence Audit shall be continued with the
investigation, but the investigation is terminated because no
prosecution performed as referred to in Article 44B of the Law
of KUP.
Article 66

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 42 (1) In the event that the Taxpayer who is under Audit to examine the
fulfillment compliance of tax obligations also under the open
Preliminary Evidence Audit, the Audit to examine the fulfillment
compliance of tax obligations shall be suspended by making the
Audit progress report if the open Preliminary Evidence Audit shall
be followed by the investigation.
(2) Suspension of the Audit to examine the fulfillment compliance of
tax obligations, as referred to in clause (1), shall be performed
until:
a. investigation is terminated in accordance with Article 44A or
Article 44B of the Law of KUP; or
b. court decision for criminal offences in the field of taxation that
has permanent legal force, and the copy of the decision is
received by the Director General of Tax.
(3) Suspension of the Audit, as referred to in clause (1), shall be
notified in written to the Taxpayer.
(4) The suspended Audit, as referred to in clause (1) shall be
continued in the event that:
a. investigation is terminated due to Article 44A of the Law of
KUP; or
b. court decision for criminal offences in the field of taxation that
has permanent legal force, and the copy of the decision is
received by the Director General of Tax.
(5) The suspended Audit, as referred to in clause (1), shall be
terminated if the investigation is terminated due to Article 44B of
the Law of KUP.
Article 67
(1) In the event that the Audit is continued, as referred to in Article
65 clause (1) or Article 66 clause (4), the examination period as
referred to in Article 15, or the examination period extension as
referred to in Article 16 or Article 17 shall be extended for the
maximum period of 4 (four) months.
(2) In the event that the Audit is terminated, as referred to in Article
65 clause (2) or Article 66 clause (5), the Tax Auditor should
de3liver the Audit termination notification letter to the Taxpayer.
(3) Director General Of Tax could remains to perform the Audit in the
event that after the Audit is terminated, as referred to in Article 65
clause (2) or Article 66 clause (5), there is data other than of
which is set forth in the Article 8 clause (3) of the Law of KUP or
Article 44B of the Law of KUP.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 43 Part Eighteen
Re-Audit
Article 68
(1) Re-Audit could only be conducted based on the instruction or
approval of the Director General of Tax.
(2) Instruction or approval of the Director General of Tax to perform
the Re-Audit could be granted in the event that there is new data,
including data that previously has not been revealed.
(3) In the event that Re-Audit ,as referred to in clause (2), is resulted
addition on the predetermined amount of tax in the previous tax
assessments letter, Director General of Tax shall issue Additional
Tax Underpayment Assessment Letter.
(4) In the event that Re-Audit, as referred to in clause (2), does not
result addition on the predetermined amount of tax in the
previous tax assessments letter, Re-Audit shall be terminated by
making Summary of LHP and such termination should be notified
to the Taxpayer.
(5) In the event that Re-Audit, as referred to in clause (2), does
result addition on the predetermined amount of tax in
previous tax assessments letter, but there are the changes in
amount of fiscal loss, Director General of Taxation issues
decree regarding the fiscal loss.

not
the
the
the

(6) Decree regarding fiscal loss, as referred to in clause (5), shall be


utilized as the basis to calculate fiscal loss to the next fiscal year.
CHAPTER IV
AUDIT FOR OTHER PURPOSES
Part One
Scope, Criteria, and Type of Audit
Article 69
The scope of the Audit for other purposes in order to implement the
provisions of the tax legislation could include determination,
adjustment, or collection of material associated with the Audit
purposes.
Article 70
Audit for other purposes for implementing the provisions of the tax
legislation shall be conducted with, such as, the following criteria:
a.

the provision of Taxpayer Identification Number in ex officio other


than of which is performed based on Verification as set forth in
the Regulation of the Minister of Finance regarding Verification

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 44 procedures;
b.

removal of Taxpayer Identification Number other than of which is


performed based on Verification as set forth in the Regulation of
the Minister of Finance regarding Verification procedures;

c.

establishment or removal of theTaxable Enterpreneur other than


of which is performed based on Verification as set forth in the
Regulation of the Minister of Finance regarding Verification
procedures;

d.

Taxpayer proposes the objection;

e.

collecting material for the preparation of net income calculation


norm;

f.

adjusting the data and/ or information tool;

g.

determination of the Taxpayers located in the remote areas;

h.

determination one or moreplaces of Value Added Tax payable;

i.

Audit in for the tax collection;

j.

determination in which the production begins or extends the


period of compensatory damages in connection with the awarding
of tax incentives; and/ or

k.

fulfilling the requests for information from partners country of


Double Tax Avoidance Agreement.
Article 71

Audit for other purposes, as referred to in Article 70, could be


conducted with type of Field Audit or Office Audit.
Part Two
Audit Standard
Article 72
(1) Audit for other purposes shoud be implemented in accordance to
the Audit standards.
(2) Audit standard, as referred to in clause (1), shall be utilized as a
measure of Audit quality of which is the minimum achievement
that should be achieved in implementing Audit.
(3) Audit standard for other purposes, as referred to in clause (1,)
including the
general standards, Audit implementation
standards, and Audit results reporting standards.
Article 73

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 45 Tax Auditor who implements the Audit for other purposes should also
meet the general standards as referred to in Article 6, clause (1) and
clause (2).
Article 74
Implementation of Audit for other purposes must be conducted in
accordance with the standards of Audit implementation, namely:
a.

Audit implementation should be preceded in good preparation, in


accordance with the Audit purposes, and receive a careful
supervision;

b.

Audit scope shall be adjusted to the criteria of the conducted


Audit for other purposes;

c.

Audit shall be conducted by a Tax Auditor team that consists of 1


(one) supervisor, 1 (one) team leader, and 1 (one) or more
members of the team, and in certain circumstances a team leader
could serve as team member;

d.

Audit could be performed at the office of the Directorate General of


Tax, residence or domicile of the Taxpayer, place of business or
free-employed of the Taxpayer, and/ or in other places that is
considered necessary by the Tax Auditor;

e.

Audit shall be performed during working hours and if necessary it


could be continued outside working hours; and

f.

Audit implementation shall be documented in the form of the


KKP.
Article 75

Audit activities for other purposes should be documented in the form


of KKP, as referred to in Article 74 letter f, with respect to the following
matters:
a.

KKP shall be obliged to be prepared by the Tax Auditor and


functions as:
1) proof that the Tax Auditor has conducted the Audit based on
the Audit standard, and
2) basis for making LHP;

b.

KKP should provide an overview regarding on:


1) data, information, and/ or evidence obtained;
2) Audit procedures of which are carried out; and
3) conclusion and other matters as may be necessary relates to

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 46 the Audit.
Article 76
Audit activity for other purposes should be reported in the form of LHP
of which is prepared in accordance with reporting standards, namely:
a.

LHP shall be drafted succinctly and clearly, containing the scope


or items that are audited according to Audit purposes, containing
the Tax Auditor conclusions and also containing other related
information disclosures;

b.

LHP for other purposes shall contain at least:


1) Taxpayer identity;
2) Audit Assignment;
3) Basic (purposes) of Audit;
4) Borrowed books and documents;
5) Material to be Audited;
6) Description of the Audit results, and
7) Conclusions and proposal of the Auditor.
Part Three
Tax Auditors Obligation and Authorization
Article 77

In performing the Audit for other purposes, the Tax Auditor shall be
obliged to:
a.

submit a Field Audit Notification Letter in the event that the


conducted Audit is the type of Field Audit or Summons for Office
Audit in the event that the conducted Audit is the type of Office
Audit;

b.

show Tax Audit Identity and SP2 when Audit;

c.

show letter that contains Tax Auditor team changes to the


Taxpayers if the Tax Auditor team composition changes;

d.

explain the reason and purposes of the Audit to the Taxpayer to


be audited;

e.

deliver an Audit Questionnaire to the Taxpayer;

f.

return the books, records, and other supporting documents od


which are borrowed from the Taxpayer; and/ or

g.

conceal to other party who are not entitled to everything known or

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 47 notified to them by the Taxpayer in the Audit.


Article 78
(1) In conducting Audit for other purposes with the type of Field
Audits, Tax Auditor shall be authorized to:
a. view and/ or borrow books, records, and/ or document of
which became the basis of accounting or bookkeeping, and
other documents associated to the Audit purposes;
b. access and/ or download electronically managed data;
c. enter and inspect place or space, tangible and / or intangible
assets of which is allegedly or reasonably suspected to be
utilized for storing books, records, and/ or documents that
became the basis of accounting or bookkeeping, and other
documents, and/ or goods which associated to the Audit
purposes;
d. request oral and/ or written information from the Taxpayer;
and/ or
e. request for the required information and/ or data from the
third party that has relationship with the Taxpayer to be
audited through the head of Audit executor unit.
(2) In conducting Audit for other purposes with the type of Office
Audit, Tax Auditor shall be authorized to:
a. see and/ or borrow books, records, and/ or documents of
which became the basis of accounting or bookkeeping, and
other documents associated with the earned income, business
activities, self-employed Taxpayer, or the tax payable object;
b. request for oral and/ or written information from the
Taxpayer; and/ or
c. request for the required information and/ or data from the
third party that has relationship with the Taxpayer to be
audited through the head of Audit executor unit.
Part Four
Taxpayers Rights and Obligations
Article 79
In implementing Audit for other purposes, the Taxpayer shall be
entitled to:
a.

ask Tax Auditor to show the Tax Auditor Identity and SP2 to the
Taxpayer at the time of the Audit;

b.

ask the Tax Auditor to give the Field Audit Notification Letter, in

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 48 terms of the conducted Audit is the type of Field Audits;


c.

ask the Tax Auditor to provide an explanation of the reason and


purposes of the Audit;

d.

ask the Tax Auditor to show the letter that contains Tax Auditor
team changes if there is a change in the composition of the Tax
Auditor team; and/ or

e.

give opinion or an assessment on the Audit implementation by the


Tax Auditor through Audit Questionnaire filling.
Article 80

(1) In the implementation of the Audit for other purposes with the
type of Field Audits, the Taxpayers shall be obliged to:
a. show and lend books, records, and/ or documents of which
becomes the basis of accounting or bookkeeping, and other
documents relating with the Audit purposes;
b. provide opportunity to access and/ or download electronically
managed data;
c. provide opportunity to enter places or spaces for storing
books, records, and/ or documents which becomes the basis
of accounting or bookkeeping, and other documents, and/ or
goods associated with the Audit purposes and lend it to the
Tax Auditor; and/ or
d. provide oral and/ or written information and provided data
and/ or other required information.
(2) In the implementation of the Audit for other purposes with the
type pf Office Audit, the Taxpayer shall be obliged to:
a. show and lend books, records, and/ or documents of which
become the basis of accounting or bookkeeping, and other
documents associated with the Audit purposes; and/or
b. provide oral and/ or written information and provided data
and / or other required information.
Part Five
Audit Period
Article 81
(1) Audit for other purposes with the type of Field Audits shall be
performed in the maximum period of 4 (four) months commencing
from the date of Field Audit Notification Letter delivered to the
Taxpayer, its representative, proxy, employee, or adult family
member of the taxpayer, until the date of LHP.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 49 (2) Audit for other purposes with the type of Office Audit shall be
performed in the maximum period of 14 (fourteen) days
commencing from the date of the Taxpayer, its representative,
proxy, employee, or adult family member of the taxpayer, comes to
fulfill the Summon for office Audit until the date of LHP.
(3) In the event that the Audit period, as referred to in clause (1) or
clause (2) ends, the Audit should be completed.
(4) In the event that the Audit for other purposes for the removal
request of Taxpayer Identification Number, as referred to in Article
70 clause b, Audit period, as referred to in clause (1) or clause (2),
should regard the
completion period of removal request of
Taxpayer Identification Number, as referred to in Article 2 clause
(7) of the Law of KUP.
(5) In the event that the Audit for other purposes for the removal
request of Taxable Enterpreneur, as referred to in Article 70 letter
c, the Audit period, as referred to in clause (1) or clause (2),
should regard the completion period of the removal request of the
Taxable Enterpreneur, as referred to in Article 2 clause (9) of the
Law of KUP.
Part Six
SP2 and Letter That Contains Tax Auditor Team Changes
Article 82
(1) Field Audit for other purposes for implementing the provisions of
the tax legislation shall be performed by the Tax Auditor of which
is incorporated in Tax Auditor team based on the SP2.
(2) SP2, as referred to in clause (1), shall be issued for one or several
Tax Period in a part of Fiscal Year or the same Fiscal Year for one
Part of Fiscal Year or a Fiscal Year for one Taxpayer.
(3) In the event that the Tax Auditor team composition need to be
changed, head of Audit Executor unit doesnt need to update the
SP2 but it should issue the letter that contains Tax Auditor team
changes.
Part Seven
Audit Notification and Summon
Article 83
(1) In the event that the Audit for other purposes performed with the
type of Field Audits, Tax Auditor shall notify the Taxpayer about
Field Audit to be performed by submitting the Field Audit
Notification Letter.
(2) In the event that the Audit for other purposes performed with the

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 50 type of Office Audit, the Tax Auditor shall notify the Taxpayer
about the Office Audit to be performed by submitting the
Summons for Office Audit.
(3) Field Audit Notification Letter, as referred to in clause (1), or
Summons for Office Audit, as referred to in clause (2) shall be
issued for a Tax Period, Part of the Fiscal Year, or Fiscal Year as
stated in the SP2.
Article 84
(1) Field Audit Notification Letter, as referred to in Article 83 clause
(1), could be submitted directly to the Taxpayer at the time of
commencement of Field Audit or delivered through facsimile,
registered postal service or other registered corrier services.
(2) In the event that the Field Audit Notification Letter is delivered
directly and the taxpayer is not in place, the Field Audit
Notification Letter could be submitted to:
a. its representative or the Taxpayers proxy; or
b. party who could represent the Taxpayer, namely:
1) employee of the Taxpayer who is according to the Tax
Auditor could represent the Taxpayer, in terms of the Audit
conducted against the corporate Taxpayer; or
2) adult family member of the Taxpayer who is according to
the Tax Auditor could represent the Taxpayer, in terms of
the Audit conducted against individual Taxpayer.
(3) Summons for Office Audit, as referred to in Article 83 clause (2),
could be submitted through fax, registered postal service or other
registered courier service.
(4) In the event that the party, as referred to in clause (2) could not
be found, Field Audit Notification Letter delivered through postal
service or other courier services and the Field Audit Notification
Letter shall be deemed has been delivered.
Part Eight
Documents Borrowing
Article 85
(1) Books, records, and documents as well as data, and other
borrowed information should be adjusted to the purposes and
criteria of the Audit for other purposes as referred to in Article 70.
(2) Borrowing of books, records, and documents as well as data, and
other information should be conducted in accordance with the
provision of Article 28 and Article 29.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 51 Part Nine
Audit Refusal
Article 86
(1) In case the Taxpayer, its representative, or the Taxpayers proxy
who is under Field Audit for other purposes certifies refusing to
perform the Audit includes refusing to receive the Field Audit
Notification Letter then the Taxpayer, its representative, or the
Taxpayers proxy should sign the letter of Audit refusal.
(2) In case the Taxpayer, its representative, or the Taxpayers proxy
refuses to sign such letter of Audit refusal, as referred to in clause
(1), Tax Auditor shall make the minute of Audit refusal of which is
signed by the Tax Auditor team.
Article 87
(1) In case the Taxpayer, its representative, or the Taxpayers proxy
under Office Audit for other purposes fulfills the Summons for
Office Audit but certifies refusing to perform the Audit, the
Taxpayer, its representative, or the Taxpayers proxy should sign
the statement letter of Audit refusal.
(2) In case the Taxpayer, its representative, or the Taxpayers proxy
refuses to sign the statement letter of Audit refusal, as referred to
in clause (1), the Tax Auditor shall make the minute of statement
letter of Audit of which is signed by the Tax Auditor team.
Article 88
(1) Based on the Statement letter of Audit refusal or the minute of
Audit refusal, as referred to in Article 86 and Article 87, the
Taxpayers request could not be processed or could not be
considered in terms of the Audit for other purposes is performed
for:
a. determination of Taxpayer located in remote areas; or
b. determination when production begins or extend the period of
compensatory damages in connection with the awarding of tax
incentives,.
(2) Based on the statement letter of Audit refusal statement or the
minute of the Audit refusal, as referred to in Article 86 and Article
87, Taxpayer shall be given the Taxpayer Identification Number
established as Taxable Entrepreneur in ex officio in terms of the
Audit performed for other purposes is performed for:
a. granting the Taxpayer Identification Number in ex officio; and
/ or

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 52 b. Establishment of the Taxable Entrepreneur in Ex officio.


(3) Based on the Statement letter of Audit refusal or the minute of the
Audit refusal, as referred to in Article 86 and Article 87, the
Taxpayers request shall not be granted in the event that the Audit
for other purposes is performed for:
a. removal of Taxpayer Identification Number; and/ or
b. Establishment or removal of Taxable Entrepreneur.
Part Ten
Taxpayer and Third Party Explanation
Article 89
(1) In the implementation of the Audit for other purposes, through
the head of the Audit executor unit, Tax Auditor also could
summon the Taxpayer to obtain the more detailed explanation or
request for information and/ or evidence cooperated with the
Audit to any third party, as referred to in Article 35 of the Law of
KUP.
(2) Information request to the Taxpayer or to any third party, as
referred to in clause (1), shall be implemented in accordance with
the provision as referred to in of Article 39 and Article 40.
CHAPTER V
SUBMISSION OF AUDIT QUESTIONNAIRE
Article 90
(1) In order to improve the quality and the accountability of the Audit,
Tax Auditor shall submit the Audit questionnaire to the Taxpayer
to be audited.
(2) In event that the performed Audit constitutes an Audit to examine
the fulfillment compliance of tax obligation, the submission of
Audit Questionnaire, as referred to in clause (1) shall be
conducted at the meeting with the Taxpayer as referred to in
Article 27.
(3) In the event that the performed Audit constitutes an Audit for
other purposes for implementing the provisions of the tax
legislation, Audit Questionnaire submission, as referred to in
clause (1), shall be submitted at the time of the Field Audit
Notification Letter submission or at the time the Taxpayer come to
fulfill the Summons for Office Audit.
(4) Taxpayers could submit the completed Audit Questionnaire to:
a. Director of Audit and Collection in terms of the Audit Executor

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 53 Unit is the Directorate of Audit and Collection; or


b. Head of Regional Office of the Directorate General of Tax in
terms of the Audit Executor Unit is the Regional Office of the
Directorate General of Tax or Tax Office.
CHAPTER VI
MISCELLANEOUS PROVISIONS
Article 91
Tax Auditor shall not be subject to the sanctions in the case of the
performed Audit is in accordance with the Audit standards, and it is
implemented based on good faith and in accordance with the
provisions of the tax legislation.
Article 92
Audit standards to examine the fulfillment compliance of tax
obligation, as referred to in Article 6, and the Audit standards for
other purposes, as referred to in Article 72, shall be set out with the
Regulation of Director General of Tax.
Article 93
(1) Document in the form of:
a. Tax Auditor Identity as referred to in Article 11 letter b;
b. SP2 as referred to in Article 24 clause (1);
c. letter contains Tax Auditor team changes as referred to in
Article 24 clause (3); and
d. letter of assignment to assist the implementation of Audit as
referred to in Article 23 clause (4),
shall be made using the format according to the sample as listed
in Appendix I of which constitutes an integral part of the
regulation herein.
(2) Document in the form of:
a. Field Audit Notification Letter as referred to in Article 25
clause (1);
b. Summons for Office Audit as referred to in Article 25 clause
(2), and
c. minute of the meeting result as referred to in Article 27 clause
(5),
shall be made using the format according to the sample as listed
in Appendix II of which constitutes an integral part of the

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 54 regulation herein.
(3) Documents in the form of:
a. request letter of borrowing of books, records, and documents
as referred to in Article 28 clause (1) letter b, and Article 28
clause (2) letter c;
b. list of books, records, and documents that shall be obliged to
be borrowed as referred to in Article 28 clause (1) letter b and
Article 28 clause (2);
c. proof of borrowing and returning books, records, and
documents as referred to in Article 28 clause (1) letter a,
Article 28 clause (2) letter b, and Article 28 clause (4);
d. statement of authenticity of documents and / or data from the
Taxpayer as referred to in Article 28 clause (5);
e. first warning letter/ second warning letter as referred to in
Article 28 clause (6);
f.

list of books, records, and documents that has not been


borrowed as referred to in Article 28 clause (7);

g. minute of non-fulfillment for the borrowing of books, records,


and documents as referred to in Article 30 clause (1);
h. minute of the fulfillment for the borrowing of all books,
records, and documents as referred to in Article 30 clause (2),
shall be made using the format in accordance with the samples as
listed in Appendix III of which constitutes as an integral part of
the regulation herein.
(4) Documents in the form of:
a. seal sign as referred to in Article 33 clause (1);
b. minute of sealing as referred to in Article 33 clause (4);
c. minute of broken/ missing seal sign as referred to in Article
34 clause (4), and
d. minute of seal opening as referred to in Article 34 clause (5),
shall be made using the format in accordance with the samples as
listed in Appendix IV of which constitutes as an integral part of
the Regulation herein.
(5) Documents in the form of:
a. Statement letter of Audit refusal as referred to in Article 35
clause (2), Article 36 clause (1), Article 37 clause (1);

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 55 b. minute of Audit refusal as referred to in Article 35 clause (3),


Article 36 clause (2), Article 37 clause (2);
c. statement letter of refusal to assist the smoothness of Audit as
referred to in Article 36 clause (6);
d. minute of the refusal to assist the smoothness of Audit as
referred to in Article 36 clause (7), and
e. minute of non-fulfilling the summon as referred to in Article
37 clause (3),
shall be made using the format in accordance to the samples as
listed in Appendix V of which constitutes as an integral part of the
Regulation herein.
(6) Documents in the form of:
a. summon to provide information as referred to in Article 39
clause (1), and
b. minute of Taxpayer provision of information as referred to in
Article 39 clause (3),
shall be made using the format in accordance to the samples as
listed in Appendix VI of which constitutes as an integral part of
the Regulation herein.
(7) Documents in the form of:
a. SPHP and Audit findings list as referred to in Article 41 clause
(1);
b. statement letter of refusal to receive the SPHP as referred to in
Article 41 clause (3) and the acknowledgement of the refusal to
receive the SPHP as referred to in Article 41 clause (4);
c. statement letter of Audit results approval as referred to in
Article 42 clause (1) letter a;
d. notification letter of period extension responses submission
from the Taxpayer as referred to in Article 42 clause (4);
e. minute of non-submission written response against SPHP as
referred to in Article 42 clause (6);
f.

invitation for Audit Result Final Discussion as referred to in


Article 43 clause (2);

g. treatise of the discussion as referred to in Article 44 clause (1)


to clause (6);
h. request letter of discussion with the Audit Quality Assurance
Team as referred to in Article 47 clause (1);

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 56 i.

invitation to attend the discussion with the Audit Quality


Assurance Team as referred to in Article 50 clause (1);

j.

treatise of Audit Quality Assurance Team as referred to in


Article 53 clause (1);

k. minute of the Audit Results Final Discussion and the treatise


of final discussion result as referred to in Article 44 clause (1),
clause (2), clause (4), and clause (6), Article 45 clause (2),
Article 46 clause (2) , and Article 54;
l.

summons to sign the minute of the Audit Result Final


Discussion as referred to in Article 55 clause (1), and

m. minute of the Taxpayer's absence in the Audit Result Final


Discussion as referred to in Article 44 clause (2), clause (4),
and clause (6), and Article 53 clause (4),
shall be made using the format in accordance to the samples as
listed in Appendix VII of which constitutes an integral part of the
regulation herein.
(8) Report of the Disclosure of untruth fulfilling of Tax Return, as
referred to in Article 61 clause (1), shall be made using the format
in accordance to the sample as listed in Appendix VIII of which
constitutes as an integral part of the Regulation herein.
(9) Documents in the form of:
a. notification of Examination period extension as referred to in
Article 18;
b. notification of Audit suspension of which is improved to the
Preliminary Evidence Audit as referred to in Article 64 clause
(2);
c. notification of Audit termination as referred to in Article 67
clause (4), and
d. Audit Questionnaires as referred to in Article 90 clause (1),
shall be made using the format in accordance with the sample as
listed in Appendix IX of which constitutes as an integral part of
the Regulation herein.
(10) Decree of the establishment of fiscal loss based on the Re-Audit,
as referred to in Article 68 clause (5), shall be made using the
format in accordance with the sample as listed in Appendix X of
which constitutes as an integral part of the Regulation herein.
CHAPTER VII
TRANSITIONAL PROVISIONS
Article 94

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 57 By the promulgation of this Ministerial Regulation:


a.

over SP2 of which is issued before the enactment of this


Ministerial Regulation and the Audit that has not been completed,
the settlement process is then performed based on the provisions
as regulated in the Regulation herein;

b.

over Audit of which is followed by the Preliminary Evidence Audit


and have been made the Summary of LHP, could be carried out an
Audit for the issuance of tax assessments letter as long as in the
Preliminary Evidence Audit results there is no indication of
criminal offenses in the field of taxation.
CHAPTER VIII
CLOSING PROVISIONS
Article 95

At the time this Ministerial Regulation come into effect:


a.

Regulation of the Minister of Finance Number 191/PMK.03/2007


concerning The Issuance of Tax Assessment Letter On Tax
Overpayment Refund Request Against The Taxpayer Who is Under
Audit On The Preliminary Evidence of Criminal Act in Taxation;

b.

Regulation of the Minister of Finance Number 198/PMK.03/2007


concerning Sealing Procedures For Audit in Taxation;

c.

Regulation of the Minister of Finance Number 199/PMK.03/2007


concerning Procedures for Tax Audit;

d.

Regulation of the Minister of Finance Number 82/PMK.03/2011


concerning the Amendment on the Regulation of the Minister of
Finance Number 199/PMK.03/2007 concerning Procedures for
Tax Audit,

shall be revoked and declared null and void.


Article 96
This Ministerial Regulation shall be come into force on February 1,
2013.
For public cognizance, it is ordered to promulgate this Ministerial
Regulation by placing in the State Gazette of the Republic of
Indonesia.

Stipulated in Jakarta
on January 7, 2013

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 58 MINISTER OF FINANCE OF THE


REPUBLIC OF INDONESIA,
Signed
AGUS DW MARTOWARDOJO
Promulgated in Jakarta
on January 7, 2013
MINISTER OF JUSTICE AND HUMAN RIGHTS
OF THE REPUBLIC OF INDONESIA,
Signed
AMIR SYAMSUDIN
OFFICIAL GAZETTE OF THE REPUBLIC OF INDONESIA YEAR 2013 NUMBER 47

APPENDIX I
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

A. FORMAT OF TAX AUDITOR IDENTITY:


MINISTRY OF FINANCE OF THE REPUBLIC
OF INDONESIA
THE DIRECTORATE GENERAL OF TAX
.. (1)

TAX AUDITOR
IDENTITY

Inside display
14 cm
MINISTRY OF FINANCE OF THE REPUBLIC OF
INDONESIA
THE DIRECTORATE GENERAL OF TAX

.. (1)
TAX AUDITOR
IDENTITY

Number
: .. (2)
Valid until : .. (3)

Photograph
(4)

Name
: . (6)
NIP
: .. (7)
Rank/Class
: (8)
Position
: ... (9)
Is an employee of the Directorate General
of Taxation or an Expert who authorized to
perform an Audit in the field of taxation
based on Law Number 6 Year 1983

DJP

concerning General Tax Provisions and


Procedures as several times amended
lastly by Law Number 16 Year 2009 in
the region of .(10)
, (11)
On behalf of DIRECTOR GENERAL OF TAX
(12)

Signature
.......... (5)
(13)
NIP

9 cm

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2FILLING INSTRUCTION FOR TAX AUDITOR IDENTITY


Form
Size

:
:

square, with cover, and be folded


length
: 14 cm
width
: 9 cm

Color:
Inside Display

Basic color
Writing color

: White with transparent DJP writing


: Black

Basic color
Writing color

: Dark blue
: Yellow gold

Outside Display/
Cover
:
Number (1)

Number (2)

Filled with the office name that issued the Tax Auditor ID
Card
Filled with Number: ../TPPP/./20 as follows:
a.
b.
c.

Number (3)

Number
Number
Number
Number
Number
Number
Number

(4)
(5)
(6)
(7)
(8)
(9)
(10)

:
:
:
:
:
:
:

Number (11)

Number (12)

Number (13)

Directorate of Audit and Collection by using number:


/TPPP/PJ.../20
DJP
Regional
Office
by
using
number:
/TPPP/BD.../20
KPP by using number: /TPPP/WPJ/KP/20

Filled with date, month, and year of the end of the Tax
Auditor Identity validity period.
a photograph sized 2 x 3 with blue background.
Tax Auditor signature
Filled with name of the Tax Auditor.
Filled with NIP of the Tax Auditor.
Filled with rank and class of the Tax Auditor.
Filled with position of the Tax Auditor
Filled with DJP Head Office (Directorate of Audit and
Collection), filled with: all over Indonesia, If issued by Tax
Office, filled with: name of the Audit Executor Unit.
Filled with location and date of the Tax Auditor Identification
was issued.
Filled with position name of the official who was signed the
Tax Auditor Identification.
Filled with signature, name, NIP, and position stamp of the
official who was signed the Tax Auditor Identification.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3B. FORMAT OF TAX AUDIT WARRANT


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
TAX AUDIT WARRANT
Number: PRIN-.. (2)

To you whose name is mentioned below:


NUMBER

NAME/NIP

RANK/CLASS

POSITION

(3)

(4)

(5)

(6)

It is ordered to perform Audit in the field of taxation in accordance with the Law
Number 6 Year 1983 concerning General Tax Provisions and Procedures as several
times amended lastly by Law Number 16 Year 2009 to the Taxpayer:
Name
: .
(7)
TIN
Address

:
: .

Period & Fiscal Year :


(10)
Audit Code/ Criteria :
()
(11)
Audit Purposes
:
(12)

TAX

.., .
(13)
On behalf of THE DIRECTORATE GENERAL OF
....,
(14)
..
(15)
NIP

Copy to:
Director General Of Tax

(8)
(9)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4FILLING INSTRUCTION FOR TAX AUDIT WARRANT


Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)

:
:
:
:
:
:

Number
Number
Number
Number

(7)
(8)
(9)
(10)

:
:
:
:

Filled with letterhead


Filled with SP2 Number
Filled with sequence number
Filled with name and NIP of the Tax Auditor
Filled with rank and class of the Tax Auditor
Filled with position in the Tax Auditor team, which are
supervisor, team leader, team member.
Filled with name of the Taxpayer to be audited
Filled with Tax Identification Number of the Taxpayer to be audited
Filled with the address of the Taxpayer to be audited
Filled with Tax Period and Fiscal Year which will be audited
Example:
1. The Audit is performed for Tax Period of January to May of
2001, then it will be filled:
0 1 1 1
0 5 1 1
2. The Audit is performed for Fiscal Year of 2011 and the
accounting year is the same with calendar year, then it will be
filled:
0 1 1 1
1 2 1 1
3. The Audit is performed for Fiscal Year of 2011, but the
accounting year commencing from April 1, 2011 until March
31, 2012, then it will be filled:
0

0 3 1 2

Number (11) : Filled with Audit code and Audit criteria based on the Audit code
and criteria of the applicable provisions, example: 1182 (routinely
overpayment All Kind of Taxes.
Number (12) : Filled with Audit Purposes, which are to:
a. Examine the fulfillment compliance of tax obligations; or
b. Other purposes in order to implement the provisions of tax
legislation.
Number (13) : Filled with location and date when the SP2 was issued.
Number (14) : Filled with position name of the official who signed the letter.
Number (15) : Filled with signature, name, NIP, and position stamp of the official
who signed the letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5C. FORMAT OF LETTER THAT CONTAINS TAX AUDITOR TEAM CHANGES:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
REVISED TAX AUDIT WARRANT
Number: PRIN-P- . (2)

In order to continue the Audit on the Taxpayer:


Name

(3)

TIN
:
Address
:
SP2 number and date :
Hereby we ordered to the following names:

(4)
(5)
(6)

NUMBER

NAME/NIP

RANK/CLASS

POSITION

DESCRIPTION

(7)
To replace:
NUMBER

(8)

(9)

(10)

(11)

NAME/NIP

RANK/CLASS

POSITION

DESCRIPTION

(12)
(13)
(14)
(15)
(16)
to perform Audit in the field of taxation in accordance with the Law Number 6 Year
1983 concerning General Tax Provisions and Procedures as amended lastly by Law
Number 16 Year 2009.
., . (17)
On behalf of THE DIRECTORATE GENERAL OF TAX
..., (18)
. (19)
NIP
Copy to:
1. Director General of Tax
2. . (20)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6FILLING INSTRUCTION OF LETTER CONTAINED TAX AUDITOR TEAM CHANGES


Number
Number
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)

:
:
:
:
:
:
:
:

Number (9)

Number (10) :
Number (11) :
Number (12) :
Number (13) :
Number (14) :
Number (15) :
Number (16) :
Number (17) :
Number (18) :
Number (19) :
Number (20) :

Filled with letterhead.


Filled with number of SP2 Changes.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with number and date of the SP2.
Filled with sequence number.
Filled with name and NIP of the Tax Auditor that assigned to
complete the audit.
Filled with rank and class of the Tax Auditor that assigned to
complete the audit.
Filled with position in the Tax Auditor team that assigned to
complete the audit, which are supervisor, team leader, or team
member.
Filled with Auditor status, replacing or adding.
Filled with sequence number.
Filled with name and NIP of the Tax Auditor that reassigned or
replaced.
Filled with rank and class of the Tax Auditor that re-assigned or
replaced.
Filled with position in the Tax Auditor team that reassigned or
replaced, which are supervisor, team leader, or team member.
Filled with description relating the cause of Tax Auditor team
composition changing.
Filled with place and date when the SP2 Changes was issued.
Filled with position name of the official who signed the letter.
Filled with signature, name, NIP and position stamp of the official
who signs the letter.
Filled with name of the Taxpayer concerned.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7D. FORMAT OF LETTER OF ASSIGNMENT TO ASSIST THE IMPLEMENTATION OF


AUDIT
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)

LETTER OF ASSIGNMENT TO ASSIST THE IMPLEMENTATION OF AUDIT


Number: (2)
Name

In connection with the implementation of audit on the Taxpayer:


: .

(3)

TIN

(4)

Address

: ....

(5)

SP2 Number and date : .

(6)

Hereby we assign you:


Name

: .

(7)

NIP

: .

(8)

Occupation / Position : .

(9)

Address

: .
(10)

as an Expert to assist the implementation of Audit in accordance with your


expertise in the field of . (11).
, . (12)
(13)
(14)
NIP

Copy to:
1.
2. ...

(15)
(16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8FILLING INSTRUCTION OF
LETTER OF ASSIGNMENT TO ASSIST THE IMPLEMENTATION OF AUDIT
Number (1)
Number (2)

: Filled with letterhead


: Filled with number of letter of assignment to assist the
implementation of audit
Number (3)
: Filled with name of the audited Taxpayer
Number (4)
: Filled with Tax Identification Number of the audited Taxpayer
Number (5)
: Filled with the address of the audited Taxpayer
Number (6)
: Filled with number and date of SP2
Number (7)
: Filled with name of the expert who was assigned to assist the
implementation of the audit.
Number (8)
: Filled with NIP of the expert who is assigned to assist the
implementation of the audit if the expert is a Civil Servant.
Number (9)
: Filled with occupation/position of the expert who is assigned to
assist the implementation of the audit.
Number (10) : Filled with the address of the expert who is assigned to assist the
implementation of the audit.
Number (11) : Filled with the expertise owned by the expert.
Number (12) : Filled with location and date when the letter of assignment to
assist the implementation of audit is issued.
Number (13) : Filled with position of the official who issues the letter, which is
Director General of Taxation in directly or in terms of not the
Director General of Taxation then it will be filled by on behalf of
Director General of Taxation.
Number (14) : Filled with signature, name, NIP, and position stamp of the official
who was signed the letter, which is Director General of Tax in
directly or in terms of not the Director General of Tax then it will
be filled by on behalf of Director General of Tax.
Number (15) : Filled with head of the Audit executor unit that performed the
audit.
Number (16) : Filled with name of the audited Taxpayer.
The copy as its
MINISTER OF FINANCE OF THE
original version
REPUBLIC OF INDONESIA
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION
Signed
OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
AGUS D.W.
MARTOWARDOJO

APPENDIX II
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

A.

FORMAT OF THE NOTIFICATION LETTER FOR FIELD AUDIT:


MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA
DIRECTORATE GENERAL OF TAX
(1)

Ministry
of finance
logo

Number
: .. (2)
., .. (3)
Subject
: Field Audit Notification
. (4)
Dear Sir/ Madam,
In connection with the Audit Order Letter number .. date
.. (5) herby we inform that:
Number
Name/NIP
Rank/Class
Position
(6)

(7)

(8)

(9)

It is ordered to perform Field Audit in the field of taxation within maximum period
of 6 (six) months on your company/occupation as follows:
Name

:
(10)

TIN

:
(11)
:
(12)

Address

Tax Period and Fiscal Year :


(13)
Audit Purposes
:
(14)

For the Audit smoothness, we ask you to show and/or borrow books or
records and documents, to give full assistance, and to give the information
required.
Refusing to be audited or does not assist the smoothness of audit, could be
subjected to sanction in accordance with the provisions in Law Number 6 Year
1983 concerning General Tax Provisions and Procedures as several times amended
lastly by Law Number 16 Year 2009.
Thank you for taking this into your concern.
Faithfully Yours
..
(15)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2Received by
: (17)
Position
: (18)
Date
: ... (19)
Signature/ stamp : ... (20)

NIP
16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3FILLING INSTRUCTION OF THE NOTIFICATION LETTER FOR FIELD AUDIT


Number (1)
Number (2)
Number (3)
Number
Number
Number
Number
Number
Number

(4)
(5)
(6)
(7)
(8)
(9)

Number
Number
Number
Number

(10)
(11)
(12)
(13)

: Filled with letterhead


: Filled with number of Field Audit Notification Letter
: Filled with location and date when the Field Audit Notification Letter
is issued.
: Filled with name and address of the audited Taxpayer.
: Filled with number and date of SP2
: Filled with sequence number
: Filled with name and NIP of the Tax Auditor
: Filled with Rank and Class of the Tax Auditor
: Filled with position in Tax Auditor Team who is supervisor, team
leader, or team member.
: Filled with name of the Taxpayer that will be audited.
: Filled with Tax Identification Number of the Taxpayer to be audited.
: Filled with the address of the Taxpayer to be audited.
: Filled with Tax Period and Fiscal Year to be audited.
Example:
1.
2.

3.

The Audit was performed for Tax Period of January to May of


2001, then it will be filled:
0 1 1 1
0 5 1 1
The Audit was performed for Fiscal Year of 2011 and the
accounting year is the same with calendar year, then it will be
filled:
0 1 1 1
1 2 1 1
The Audit was performed for Fiscal Year of 2011, but the
accounting year commencing from April 1, 2011 until March
31, 2012, then it will be filled:
0 4 1 1
0 3 1 2

Number (14) : Filled with the Audit purposes, which is:


a.
b.

Examining the fulfillment compliance of tax obligations; or


Other purposes in order to implement the provisions of tax
legislation.

Number (15) : Filled with position name of the official who signs the Letter.
Number (16) : Filled with signature, name, NIP, and position stamp of the official
who signs the Letter.
Number (17) : Filled with the name who receives the Field Audit Notification Letter.
Number (18) : Filled with position of a person who receives the Field Audit
Notification Letter.
Number (19) : Filled with the date when the Field Audit Notification Letter is
received.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4Number (20) : Filled with signature of a person and stamp of the company who
receives the Field Audit Notification Letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5B.

FORMAT OF SUMMON FOR OFFICE AUDIT:


MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA
DIRECTORATE GENERAL OF TAX
(1)

Ministry
of finance
logo

Number
: (2
(3)
Attachment : (4)
Subject
: Summon For Office Audit

Dear Sir/Madam ..
. (5)
In connection with the SP2 number .. date (6), hereby
we inform that:
Number

Name/NIP

Rank/Class

Position

(7)

(8)

(9)

(10)

it is ordered to perform an Office Audit in the field of taxation to the


company/occupation as follows:
Name
: ..
(11)
TIN
Address

:
: ..

(12)
(13)

Tax Period and Fiscal Year :


Audit Purposes
: ..

(14)
(15)

For the smoothness of the Audit, we expects your presence to our office by
bringing books, records, and supporting documents as attached, giving full
assistant, and give information required on:
Day/date
Venue
Time

: ....
: .
: .

(16)
(17)
(18)

Refusing to be audited or does not assist the smoothness of audit, could be


subjected to sanction in accordance with the provisions in Law Number 6 Year
1983 concerning General Tax Provisions and Procedures as several times amended
lastly by Law Number 16 Year 2009.
In witness whereof for your concern and thank you for your cooperation.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6.
(19)

.
NIP .
(20)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7FILLING INSTRUCTION OF SUMMON FOR OFFICE AUDIT


Number (1)
Number (2)
Number (3)
Number
Number
Number
Number
Number
Number
Number

(4)
(5)
(6)
(7)
(8)
(9)
(10)

Number (11)
Number (12)
Number (13)

: Filled with letterhead.


: Filled with number of Summon For Office Audit
: Filled with location and date when the Summon For Office Audit
was issued.
: Filled with number of document attached.
: Filled with name and address of the audited Taxpayer.
: Filled with number and date of the SP2.
: Filled with sequence number.
: Filled with name and NIP of the Tax Auditor.
: Filled with rank and class of the Tax Auditor.
: Filled with position in Tax Auditor Team, which is supervisor,
team leader, or team member.
: Filled with name of the Taxpayer to be audited.
: Filled with Tax Identification Number of the Taxpayer to be
audited.
: Filled with address of the Taxpayer to be audited.

Number (14) : Filled with Tax Period and Fiscal Year to be audited.
Example:
1.
2.

3.

The Audit was performed for Tax Period of January to May of


2001, then it will be filled:
0 1 1 1
0 5 1 1
The Audit was performed for Fiscal Year of 2011 and the
accounting year is the same with calendar year, then it will be
filled:
0 1 1 1
1 2 1 1
The Audit was performed for Fiscal Year of 2011, but the
accounting year commencing from April 1, 2011 until March
31, 2012, then it will be filled:
0 4 1 1
0 3 1 2

Number (15) : Filled with Audit purposes, which is:


a.
b.
Number
Number
Number
Number
Number

(16)
(17)
(18)
(19)
(20)

Examining the fulfillment compliance of tax obligations; or


Other purposes in order to implement the provisions of tax
legislation.

: Filled with day and date when the Taxpayer asked to be present.
: Filled with meeting location.
: Filled with time of the meeting.
: Filled with position name of the official who signs the letter.
: Filled with signature, name, NIP and position stamp of the official
who signs the letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8C. FORMAT OF THE MINUTE OF MEETING RESULT WITH TAXPAYER:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAXATION
(1)
THE MINUTE OFMEETING RESULT TAXPAYER

Today . date month .. year .. (2) pursuant


to the Tax Audit Warrant number . date (3), we who are
mentioned below:
Number
Name /NIP
Rank / Class
Position
(4)
(5)
(6)
has been conduct a meeting with:
Name
:
(8)
Occupation
:
(9)
Address
:
(10)

(7)

In this case acted as:


Taxpayer
of the Taxpayer:
Name
TIN
Address

Representative

Proxy

(11)

: ..
:
: ..

(12)
(13)
(14)

To:
1.
2.
3.

4.
5.

explain the reason and purposes of the audit;


explain rights and obligations of the Taxpayer during and after the audit
implementation;
explain the right of the Taxpayer to apply the request to be held the discussion
with the Audit Quality Assurance Team in the event that there are any audit
results that have not been agreed between the Tax Auditor Team with the
Taxpayer in the Audit Result Final Discussion;
explain books, records, and/or documents to be borrowed from the Taxpayer.
submit and to explain the Audit Questioner.
In witness whereof this minute of the meeting result with the Taxpayer is
made in truthfully and signed by:
Taxpayer/ Representative / Proxy/
Party who represents*)

Tax Auditor Team:


Supervisor,

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-9.. (15)

.
NIP . (16)

Team Leader,

.
NIP . (17)

Team Member,
.
NIP . (18)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 10 FILLING INSTRUCTION FOR THE MINUTE OF MEETING RESULT WITH TAXPAYER


Number (1)
Number (2)

: Filled with letterhead.


: Filled with day, date, month, and year when the minute of meeting
result with the Taxpayer is signed.
Number (3) : Filled with number and date of the SP2.
Number (4) : Filled with sequence number.
Number (5) : Filled with name and NIP of the Tax Auditor.
Number (6) : Filled with rank and class of the Tax Auditor.
Number (7) : Filled with position in Tax Auditor Team, which is supervisor,
team leader, or team member.
Number (8) : Filled with name of the Taxpayer, Taxpayers representative,
Taxpayers proxy, or other party who represents Taxpayer.
Number (9) : Filled with occupation of the Taxpayer, Taxpayers representative,
Taxpayers proxy, or other party who represents Taxpayer.
Number (10) : Filled with the address of the Taxpayer, Taxpayers representative,
Taxpayers proxy, or other party who represents Taxpayer.
Number (11) : Filled with sign on the box needed.
Number (12) : Filled with name of the audited Taxpayer.
Number (13) : Filled with Tax Identification Number of the audited Taxpayer.
Number (14) : Filled with the address of the audited Taxpayer.
Number (15) : Filled with signature and name of the Taxpayer, Taxpayers
representative, Taxpayers proxy, or other parties that representing
Taxpayer.
Annotation*) : Filled with appropriate choice.
Number (16) : Filled with signature, name and NIP of the Tax Auditor team
supervisor.
Number (17) : Filled with signature, name and NIP of the Tax Auditor team leader.
Number (18) : Filled with signature, name and NIP of the Tax Auditor team
member.
The copy as its
MINISTER OF FINANCE OF THE
original version
REPUBLIC OF INDONESIA
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION OF
Signed
THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
AGUS D.W.
MARTOWARDOJO

APPENDIX III
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

A.

FORMAT OF REQUEST LETTER OF BORROWING BOOKS, RECORDS, AND


DOCUMENTS:
Ministry
of finance
logo

Number
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAXATION
.. (1)
:
:
:
:

.. (2)
, .. (3)
Immediately
.. (4)
Request of Borrowing Books, Records, and Documents

Dear Sir/Madam ..
.
. (5)
In connection with the implementation of the Tax Audit Warrant number
.. date . (6), hereby we asked to you to borrow books,
records, and documents of which became a basis of accounting and bookkeeping
and other document of which are related to your business activities or selfemployment as attached in the list.
The required Books, records, and documents herein, we expect already
accepted in a maximum of 7 (seven) working days after this letter is received.
Books, records, and documents above will be returned to you after the Audit is
completed.
In witness whereof it is for your concerned and thank you for your
cooperation.
Supervisor,
.
Received by
Position
Date
Signature/ stamp

:
:
: .
: ..

(8)
(9)
(10)
(11)

.
NIP.. (7)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2FILLING INSTRUCTION OF REQUEST LETTER OF BORROWING BOOKS,


RECORDS, AND DOCUMENTS
Number (1)
Number (2)

:
:

Number (3)

Number
Number
Number
Number

(4)
(5)
(6)
(7)

:
:
:
:

Number (8)

Number (9)

Number (10) :
Number (11) :

Filled with letterhead.


Filled with number of request letter of borrowing books, records,
and documents.
Filled with location and date when the request letter of borrowing
books, records, and documents is issued.
Filled with number of attached documents.
Filled with name and address of the audited Taxpayer.
Filled with number and date of the SP2.
Filled with signature, name and NIP of the Supervisor and stamp
of the Audit Executor Unit.
Filled with name of a person who receives the request letter of
borrowing books, records, and documents.
Filled with position of a person who receives the request letter of
borrowing books, records, and documents.
Filled with date when the request letter of borrowing books,
records, and documents are received.
Filled with signature of a person and stamp of the company who
receives the request letter of borrowing books, records, and
documents.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3B.

FORMAT OF LIST OF BOOKS, RECORDS, AND DOCUMENTS THAT SHALL


BE OBLIGED TO BE BORROWED:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)

LIST OF BOOKS, RECORDS, AND DOCUMENTS THAT SHALL BE OBLIGED TO BE


BORROWED FOR AUDIT
Name of Taxpayer :
(2)
TIN
:
(3)
Taxpayers Address :
(4)
Number

Type/Name of Books, Records, Documents

Description

(5)

(6)

(7)

.,
(8)
Supervisor

..
NIP ..
9)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4FILLING INSTRUCTION OF LIST OF BOOKS, RECORDS, AND DOCUMENTS THAT


SHALL BE OBLIGED TO BE BORROWED
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)

:
:
:
:
:
:

Number (7)
Number (8)

:
:

Number (9)

Filled with letterhead


Filled with name of the audited Taxpayer
Filled with Tax Identification Number of the audited Taxpayer
Filled with address of the audited Taxpayer
Filled with sequence number
Filled with type/name of books, records, and/or other documents
that shall be obliged to be borrowed along with the fiscal year.
Filled with condition of borrowed document.
Filled with location and date when the list of books, records, and
documents that shall be obliged to be borrowed is issued.
Filled with signature, name and NIP of the Supervisor along with
stamp of the Audit Executor Unit.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5C.

FORMAT OF RECEIPT OF BORROWING AND RETURNING BOOK, RECORD,


AND DOCUMENT:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)

RECEIPT OF BORROWING AND RETURNING BOOK, RECORD, AND DOCUMENT


Name of Taxpayer

: .

(2)

TIN
:
Taxpayers Address
: .
SP2 Number and date : .

(3)
(4)
(5)

Number

Type/Name of
Book, Record,
and
Document

Description

completely /
incompletely
loaned

completely /
incompletely
returned

(6)

(7)

(8)

(9)

(10)

Received by:

Submitted by:

Date: ..
(11)

Date

(13)

...

(14)

.
NIP..

(12)

Received by:

Returned by:

Date: ..

(15)

Date: .

(17)

(16)

.
NIP

(18)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6FILLING INSTRUCTION OF THE RECEIPT OF BORROWING AND RETURNING OF


BOOK, RECORD, AND DOCUMENT
Number
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)
(7)

:
:
:
:
:
:
:

Number (8)

Number (9)

Number (10) :
Number (11) :
Number (12) :
Number (13) :
Number (14) :

Number (15) :
Number (16) :

Number (17) :
Number (17) :

Filled with letterhead.


Filled with name of the audited Taxpayer
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with number and date of the SP2.
Filled with sequence number.
Filled with borrowed books, records, and documents, both in the
form of manual and electronic data.
Filled with number and unit of borrowed books, records, and
documents, for example 1 ordner, 2 set, 3 compact disc, etc.
Filled with Complete or Incomplete for the existence of borrowed
books, records, and documents at the time of borrowing.
Filled with Complete or Incomplete for the existence of borrowed
books, records, and documents at the time of returning.
Filled with date of borrowing of books, records, and documents.
Filled with signature, name, and NIP of the Supervisor who received
the books, records, and document that borrowed.
Filled with date of submission of books, records, and documents.
Filled with signature, name, and position of the Taxpayer,
Taxpayers representative, Taxpayers proxy, or party who
represents the Taxpayer who delivers book, records, and
documents that are borrowed.
Filled with receiving date of the returning of books, records, and
documents.
Filled with signature, name, and position of the Taxpayer,
Taxpayers representative, Taxpayers proxy who receives books,
records, and documents that borrowed. In terms of the Taxpayers
representative also shall be obliged to fill its position.
Filled with date of returning books, records, and documents.
Filled with signature, name, and NIP of the Supervisor who returns
the books, records, and document that re borrowed.

Notes:
Receipt of borrowing and returning of books, records, and document, shall be made
when:
1.
2.
3.

Borrowing of Books, records and documents is conducted in Taxpayers place.


Taxpayer delivers books, records, and documents for fulfilling the attachment
in the Summons for Office Audit.
Taxpayer delivers books, records, and documents for fulfilling the Request
letter of borrowing Books, Records, and Documents (Field Audit or Office
Audit).

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7D. FORMAT OF THE STATEMENT OF AUTHENTYCITY OF DOCUMENTS AND/ OR


DATA PROVIDED:
STATEMENT LETTER
I, the undersigned below:
Name
: ....
Occupation / Position
: .
Address
: .
In this matter acting as:
Taxpayer;

Representative

(1)
(2)
(3)

Proxy

(4)

of the Taxpayer:
Name

: .

(5)

TIN
Address

:
: .

(6)
(7)

hereby certifies that for implementing the Tax Audit Warrant:


Number
:
Date
:

(8)
(7)

has delivered to the Tax Auditor in the form of photocopy and/ or electronically
managed data over the books, records, and documents that are made from and in
accordance with their original version.
In witness whereof this statement is made and signed with full
consciousness and without coercion whosoever, and we are ready to be responsible
for all legal consequences arising from this statement.
.., ..(10)
Who makes the statement

( 11)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8FILLING INSTRUCTION OF THE STATEMENT OF AUTHENTICITY OF THE


DOCUMENTS AND/ OR DATA PROVIDED
Number (1)

: Filled with name of the Taxpayer, Taxpayers representative, or the


Taxpayers proxy who signs the statement letter.
Number (2) : Filled with occupation/position of the Taxpayer, Taxpayers
representative, or the Taxpayers proxy who signs the statement
letter.
Number (3) : Filled with the address of the Taxpayer, Taxpayers representative,
or the Taxpayers proxy who signs the statement letter.
Number (4) : Filled with sign on the box required.
Number (5) : Filled with name of the Taxpayer to be audited.
Number (6) : Filled with Tax Identification Number of the Taxpayer to be audited.
Number (7) : Filled with the address of the Taxpayer to be audited.
Number (8) : Filled with number of the SP2.
Number (9) : Filled with date of the SP2.
Number (10) : Filled with location, date, month, and year when the statement letter
is made.
Number (11) : Filled with name of the Taxpayer, Taxpayers representative, or the
Taxpayers proxy who signs the statement letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-9E. FORMAT OF FIRST/ SECOND WARNING LETTER:


Ministry
of finance
logo

Number
(3)
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)
: .. (2)

.,

: Immediately
: .. (4)
: First/ Second Warning Letter*)

. (5)
Dear Sir/ Madam,
As the implementation of Audit based on Tax Audit Warrant number
date . (6), you have been asked to borrow books or
records, as well as other document relating to your business activities or selfemployment with the Request letter of borrowing Books, Records, and Documents
number .. date (7), however, up to the date of this
letter is made, you:
completely did not lend
partially borrow
books or records and document that we are required.
In connection with the foregoing, you are asked to immediately deliver the
books or records and documents as mentioned in the attached list at no later than
the date .. (9).
It is noteworthy to remind you that an Preliinary Evidence Audit or the tax
payable is calculated by ex officio could be conducted against you if you did not
meet the demand for borrowing books, records, and documents mentioned above.
Thank you for your kind attention.
Yours Faithfully
Supervisor
Received by
Position
Date
Signature/ stamp

: ...
:
:
:

(11)
(12)
(13)
(14)

.
NIP
(10)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 10 FILLING INSTRUCTION FOR THE FIRST / SECOND WARNING LETTER


Number (1)
Number (2)
Number (3)

: Filled with letterhead.


: Filled with number of the first/ second warning letter.
: Filled with location and date when the first/ second warning letter
is made.
Number (4) : Filled with number of attached document.
Annotation *) : Filled with the appropriate choice.
Number (5) : Filled with name and address of the Taxpayer who given the first/
second warning letter.
Number (6) : Filled with number and date of SP2.
Number (7) : Filled with number and date of request letter of borrowing books,
records, and documents.
Number (8) : Filled with in the box required.
Number (9) : Filled with submission deadline of borrowed books, records, and
documents.
Number (10) : Filled with signature, name, and NIP of the Supervisor and the
stamp of the Audit Executor Unit.
Number (11) : Filled with name of the person who receives the first/ second
warning letter.
Number (12) : Filled with position of the person who receives the first/ second
warning letter.
Number (13) : Filled with receiving date of the first/ second warning letter.
Number (14) : Filled with signature of the person and the company stamp who
receives the first/ second warning letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 11 F.

FORMAT OF LIST OF BOOKS, RECORDS, AND DOCUMENTS THAT HAS


NOT BEEN BORROWED:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)

LIST OF BOOKS, RECORDS, AND DOCUMENTS THAT HAS NOT BEEN


BORROWED
IN ORDER OF AUDIT

Name of Taxpayer : .

(2)

TIN

: .

(3)

Taxpayers Address : .

(4)

Number

Type/Name of Books, Records, Documents

Description

(5)

(6)

(7)

., (8)
Supervisor

NIP (9)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 12 FILLING INSTRUCTION OF LIST OF BOOKS, RECORDS, AND DOCUMENTS THAT


HAS NOT BEEN BORROWED
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)

Number (7)
Number (8)
Number (9)

:
:
:
:
:
:

Filled with letterhead.


Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with address of the audited Taxpayer.
Filled with sequence number.
Filled with type/name of books, records, and/or other documents
that has not been borrowed along with the fiscal year.
: Filled with description required.
: Filled with location and date when the list of books, records, and
documents that has not been borrowed is issued.
: Filled with signature, name and NIP of the Supervisor along with
stamp of the Audit Executor Unit.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 13 G.

FORMAT OF THE MINUTE OF NON-FULFILLMENT BORROWING BOOK,


RECORD, AND DOCUMENT:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)

THE MINUTE OF NON-FULFILLMENT BORROWING BOOK, RECORD, AND


DOCUMENT
On this day . date month .. year .. (2)
pursuant to the Tax Audit Warrant number . (3) date (4), we
hereby mentioned below as Tax Auditor team who are assigned to perform Audit to
the Taxpayer:
Name
: ..
(5)
TIN
:
(6)
Address
: .
(7)
hereby vertify that all/ part of books, records, and/ or documents, as referred to in
the Request Letter of borrowing Books, Records, and Documents number
.. (8) its borrowing is not fulfilled by the Taxpayer to the Tax
Auditor team.
In witness whereof this minutes is made in truthfully under the oath of
office, then it is closed and signed by the Tax Auditor team.
Tax Auditor Team:
Supervisor,
.
NIP . (9)
Acknowledged by:
(12)
.

NIP (13)

Team Leader,

NIP . (10)
Team member,

NIP (11)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 14 FILLING INSTRUCTION OF THE MINUTE OF NON-FULFILLMENT BORROWING


BOOK, RECORD, AND DOCUMENT

Number (1)
Number (2)

:
:

Number (3) :
Number (4) :
Number (5) :
Number (6) :
Number (7) :
Annotation *) :
Number (8) :
Number (9)

Number (10) :
Number (11) :
Number (12) :
Number (13) :

Filled with letterhead


Filled with the day, date, month and year when the minute of nonfulfillment borrowing of books, records, and documents is signed.
Filled with number of the SP2.
Filled with date of the SP2.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with the appropriate choice.
Filled with number of the Request letter of borrowing Books,
Records, and Documents.
Filled with signature, name and NIP of the Tax Auditor Team
Supervisor
Filled with signature, name and NIP of the Tax Auditor Team
leader.
Filled with signature, name and NIP of the Tax Auditor Team
member.
Filled with position name of the head of Audit Executor Unit.
Filled with signature, name and NIP, and position stamp.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 15 H.

FORMAT OF MINUTE OF THE FULFILLMENT BORROWING ALL BOOKS,


RECORDS, AND DOCUMENTS:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)

MINUTE OF FULFILLMENT BORROWING ALL BOOKS, RECORDS, AND


DOCUMENTS
On this day . date month .. year .. (2)
pursuant to the Tax Audit Warrant number . (3) date (4), we
hereby mentioned below as Tax Auditor team who are assigned to perform Audit to
the Taxpayer:
Name
: ..
(5)
TIN
:
(6)
Address
: ..
(7)
hereby certify that all books, records, and/or documents as referred to in the
Request letter of borrowing Books, Records, and Documents number
.. (8), its borrowing has been fulfilled by the Taxpayer to the Tax
Auditor team.
In witness whereof this minute is made in truthfully under the oath of office,
and then it is closed and signed by the Tax Auditor team.
Tax Auditor Team:
Supervisor,

NIP
Acknowledged by:
(12)

..

(9)

Team Leader,

NIP ..

(10)
NIP (13)
Team member,
.
.

(11)

NIP

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 16 FILLING INSTRUCTION OF MINUTE OF FULFILLMENT BORROWING ALL BOOKS,


RECORDS, AND DOCUMENTS
Number (1)
Number (2)

: Filled with letterhead


: Filled with the day, date, month and year when the minute of
fulfillment borrowing all books, records, and documents is signed.
Number (3) : Filled with number of the SP2.
Number (4) : Filled with date of the SP2.
Number (5) : Filled with name of the audited Taxpayer.
Number (6) : Filled with Tax Identification Number of the audited Taxpayer.
Number (7) : Filled with the address of the audited Taxpayer.
Annotation *) : Filled with the appropriate choice.
Number (8) : Filled with number of the Request Letter of Borrowing Books,
Records, and Documents.
Number (9) : Filled with signature, name and NIP of the Tax Auditor Team
Supervisor
Number (10) : Filled with signature, name and NIP of the Tax Auditor Team
leader.
Number (11) : Filled with signature, name and NIP of the Tax Auditor Team
member.
Number (12) : Filled with position name of the head of Audit Executor Unit
concerned.
Number (13) : Filled with signature, name and NIP, and position stamp.
Copy as its
MINISTER OF FINANCE OF THE
original version
REPUBLIC OF INDONESIA
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION
Signed
OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
AGUS D.W.
MARTOWARDOJO

APPENDIX IV
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

A. FORMAT OF SEAL SIGN

By the power pursuant to Article 30 of Law Number 6 Year 1983 on


General Provision and Tax Procedures as it has been several times
amended lastly with Law Number 16 Year 2009 Sealing due to nonfulfilling the obligation in Article 29 clause (3) of Law Number 6 Year
1983 concerning General Tax Provisions and Procedures as several
times amended lastly by Law Number 16 Year 2009 shall be
conducted.
Warning
Anyone who deliberately cuts, dispose, or damage this seal shall
be threatened with a maximum imprisonment of 2 (two) years and
8 (eight) months.

SEALED

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2FILLING INSTRUCTION OF SEAL SIGN


Form and size
Paper color
Word SEALED
Other words and margin
Ministry of finances logo

:
:
:
:
:

Seal Type

Elongated size 30 x 10 cm
White
Red colored
Black/ dark blue colored
Shaded with thin color, the size is adjusted with the
paper size.
Sticker with perforation, with the purpose when the
seal paper is affixed to the sealed place/ room, at the
time opened the seal will be broken and torn.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3B. FORMAT OF MINUTE OF SEALING:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAXATION
(1)

ACKNOWLEDGEMENT OF SEALING
On this day .. date month year
.. (2), we:
Number
Name/NIP
Rank / Class
Position
(3)
(4)
(5)
(6)
Tax Auditor on . (7) pursuant to the Audit Warrant
Number .. date (8) for Audit in the field of taxation
pursuant to Article 29 of Law Number 6 Year 1983 concerning General Provisions
and Tax Procedures as it has been several times amended lastly with Law Number
16 Year 2009, has been performed a Sealing against place or space, tangible or
intangible good in the form of:
Number
Place/Space or goods
1.
And so on.
(9)
Which are owned and/or controlled by:
Name
: (10)
TIN
: (11)
Address
: (12)
that is allegedly or reasonably suspected to be utilized as a place or tool for storing
books or records, and/ or documents, including the data processing result from the
accounting that electronically managed or by an on-line application programs
associated with the business activities or self-employment of the Taxpayer.
In witness whereof this minute is made in truthfully in accordance with the
oath of office.
, .
(
13)
Auditor,

NIP
14)
Witnesses : (15)
Number
Name
1
And so on

Signature

Notes

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4FILLING INSTRUCTION OF THE MINUTE OF SEALING


Number (1)
Number (2)
Number
Number
Number
Number
Number
Number

(3)
(4)
(5)
(6)
(7)
(8)

Number
Number
Number
Number
Number
Number
Number

(9)
(10)
(11)
(12)
(13)
(14)
(15)

: Filled with letterhead.


: Filled with day, date, month, and year when the minute of Sealing
is signed.
: Filled with sequence number.
: Filled with name and NIP of the Tax Auditor
: Filled with rank/class of the Tax Auditor.
: Filled with position in the Tax Auditor team.
: Filled with name of the Audit executor unit.
: Filled with number and date of the SP2 and the letter contained
Tax Auditor team changes in terms of changes in the Tax Auditor
team.
: Filled with name and type of sealed place/space or goods.
: Filled with name of the audited Taxpayer.
: Filled with Tax Identification Number of the audited Taxpayer.
: Filled with the address of the audited Taxpayer.
: Filled with location and date when the minute of Sealing is made.
: Filled with signature, name, and NIP of the Tax Auditor.
: Filled with name and signature of witnesses who witness the
sealing or the refusal notes and the reason.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5C. FORMAT OF THE MINUTE OF BROKEN/ MISSING SEAL SIGN:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAXATION
. (1)
MINUTE OF BROKEN/ MISSING SEAL SIGN*)

On this day date month year


(2), we
Number
Name/NIP
Rank/Class
Position
(3)
(4)
(5)
(6)
Tax Auditor on . (7) pursuant to the Audit Warrant number
.. date (8) for the Audit in the field of tax pursuant to
Article 29 of Law Number 6 Year 1983 concerning General Provisions and Tax
Procedures it has been as several times amended lastly with Law Number 16 Year
2009, stating that the seal has been broken/missing*) on the place or space,
tangible or intangible good in the form of:
Number
Place/Space or goods
1.
And so on.
(9)
Which are owned and/or controlled by:
Name
: . (10)
TIN
: . (11)
Address
: . (12)
that is allegedly or reasonably suspected to be utilized as a place or tool for storing
books or records, and/ or documents, including the data processing result from the
accounting that electronically managed or by an on-line application program
associated with the business activities or self-employment of the Taxpayer.
In witness whereof this minute is made in truthfully in accordance with the
oath of office.
,
..
(1
3)
Auditor,
.
NIP
.
(1
4)
Witnesses : (15)
Number
1
And so on

Name

Signature

Notes

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6FILLING INSTRUCTION OF THE MINUTE OF


BROKEN/ MISSING SEAL SIGN

Number (1)
Number (2)

:
:

Number
Number
Number
Number
Number
Number

:
:
:
:
:
:

(3)
(4)
(5)
(6)
(7)
(8)

Annotation *) :
Number (9) :
Number
Number
Number
Number

(10)
(11)
(12)
(13)

:
:
:
:

Number (14) :
Number (15) :

Filled with letterhead.


Filled with day, date, month, and year when the minute of broken/
missing seal sign is signed.
Filled with sequence number.
Filled with name and NIP of the Tax Auditor
Filled with rank/class of the Tax Auditor.
Filled with position in the Tax Auditor team.
Filled with name of the Audit executor unit.
Filled with number and date of the SP2 and the letter contains Tax
Auditor team composition changes in terms of changes in the Tax
Auditor team.
Filled with appropriate choice.
Filled with name and type of place/ space or goods that will be
opened the seal.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with location and date when the minute of broken/missing
seal is made.
Filled with signature, name, and NIP of the Tax Auditor.
Filled with name and signature of witnesses who witnes the
sealing or the refusal notes and the reason.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7D. FORMAT OF THE MINUTE OF SEAL OPENING:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
MINUTE OF SEAL OPENING

On this day .. date month year


.. (2), we:
Number
Name/NIP
Rank / Class
Position
(3)
(4)
(5)
(6)
Tax Auditor on . (7) pursuant to the Audit Order Letter
Number .. date (8) for Audit in the field of tax based on
Article 29 of Law Number 6 Year 1983 concerning General Provisions and Tax
Procedures as it has been several times amended lastly with Law Number 16 Year
2009, has opened the seal on place or space, tangible or intangible good in the form
of:
Number
Place/Space or goods
1.
And so
(9)
on.
Which are owned and/or controlled by:
Name
: (10)
TIN
: (11)
Address
: (12)
that is allegedly or reasonably suspected to be utilized as a place or tool for storing
books or records, and/ or documents, including the data processing result from the
accounting that electronically managed or by an on-line application program
relating the business activities or self-employment of the Taxpayer.
In witness whereof this minute is made truthfully in accordance with the
oath of office.
,
.
(
13)
Auditor,

NIP.
(
Witnesses : (15)
Number
Name
1
And so on

14)
Signature

Notes

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8FILLING INSTRUCTION OF THE MINUTE OF SEAL OPENING


Number (1)
Number (2)

: Filled with letterhead.


: Filled with day, date, month, and year when the minute of seal
opening was signed.
Number (3) : Filled with sequence number.
Number (4) : Filled with name and NIP of the Tax Auditor
Number (5) : Filled with rank/class of the Tax Auditor.
Number (6) : Filled with position in the Tax Auditor team.
Number (7) : Filled with name of the Audit executor unit.
Number (8) : Filled with number and date of the SP2 and the letter contained
Tax Auditor team composition changes in terms of changes in the
Tax Auditor team.
Number (9) : Filled with name and type of place/space or goods that the seal will
be opened.
Number (10) : Filled with name of the audited Taxpayer.
Number (11) : Filled with Tax Identification Number of the audited Taxpayer.
Number (12) : Filled with the address of the audited Taxpayer.
Number (13) : Filled with location and date when the minute of seal opening was
made.
Number (14) : Filled with signature, name, and NIP of the Tax Auditor.
Number (15) : Filled with name and signature of witnesses who witnes the sealing
or the refusal notes and the reason.
Copy as its
MINISTER OF FINANCE OF THE
original version
REPUBLIC OF INDONESIA
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION
Signed
OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
AGUS D.W.
MARTOWARDOJO

APPENDIX V
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

A. FORMAT OF STATEMENT LETTER FOR AUDIT REFUSAL:


STATEMENT LETTER AUDIT REFUSAL
I, the undersigned below:
Name
: . (1)
Occupation/Position : . (2)
Address
: . (3)
In this case acting as:
In this case acted as:
Taxpayer
Representative
Proxy
(4)
of the Taxpayer:
Name
: .

(5)

TIN
:
(6)
Address : .
(7)
In connection with the Audit by the Tax Auditor from the Directorate General of
Tax:
Number
Name/NIP
Rank / Class
Position
(8)

(9)

(10)

(11)

Pursuant to Tax Audit Warrant number (12) date .


(13) hereby certifies refusing the Audit with the reason of . (14)
In witness whereof this statement letter for Audit refusal is made and signed
with full consciousness and without coercion from whoseover, and I am ready to be
responsible for all legal consequences arising from this statement.
.., ..
(
15)
Who makes the statement,
Stamp Duty
IDR 6.000

. .
16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2FILLING INSTRUCTION OF STATEMENT LETTER AUDIT REFUSAL


Number (1)

Number (2)

Number (3)

Number
Number
Number
Number
Number
Number
Number
Number

(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)

:
:
:
:
:
:
:
:

Number
Number
Number
Number

(12)
(13)
(14)
(15)

:
:
:
:

Number (16) :

Filled with name of the Taxpayer, Taxpayers representative, or the


Taxpayers proxy who signs the statement letter for audit refusal.
Filled with occupation/position of the Taxpayer, Taxpayers
representative, or the Taxpayers proxy who signs the statement
letter for audit refusal .
Filled with address of the Taxpayer, Taxpayers representative, or
the Taxpayers proxy who signs the statement letter for audit
refusal.
Filled with sign on appropriate box.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with sequence number.
Filled with name and NIP of the Tax Auditor team.
Filled with rank/class of the Tax Auditor team
Filled with position in the Tax Auditor team, which are
supervisor, team leader, team member.
Filled with number of the SP2
Filled with date of the SP2
Filled with the reason of the Audit refusal.
Filled with location and date when the statement letter for audit
refusal is made.
Filled with signature and name of the Taxpayer, Taxpayers
representative, or the Taxpayers proxy who signs the audit refusal
statement letter

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3B. FORMAT OF THE MINUTE OF AUDIT REFUSAL:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)

THE MINUTE OF AUDIT REFUSAL


On this day . (2) date (3) month .. (4) year
.. (5) pursuant to the Tax Audit Warrant number . (6) date
(7), two are hereby mentioned below as a Tax Auditor team who are
assigned to perform Audit to the Taxpayer:
Name
:
(8)
TIN
:
(9)
Address
:
(10)
that in connection with the Audit, Taxpayer in this case is represented by:
Name
:
(11)
Occupation/Position
:
(12)
Address
:
(13)
has refused to make and sign the statement letter for refusal .
In witness whereof this minute is made in truthfully under power of the oath
of office, then it is closed and signed by the Tax Auditor team.
Tax Auditor Team:
Supervisor,

NIP (14)
Acknowledged by:
(17)

Team Leader,

NIP

(15)
NIP (18)
Team member,

NIP (16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4FILLING INSTRUCTION OF THE MINUTE OF AUDIT REFUSAL


Number
Number
Number
Number

(1)
(2)
(3)
(4)

:
:
:
:

Number
Number
Number
Number
Number
Number
Number

(5)
(6)
(7)
(8)
(9)
(10)
(11)

:
:
:
:
:
:
:

Number (12) :
Number (13) :
Number (14) :
Number (15) :
Number (16) :
Number (17) :
Number (18) :

Filled with letterhead.


Filled with the day when the minute of audit refusal is signed.
Filled with date when the minute of audit refusal is signed.
Filled with month when the acknowledgement of audit refusal is
signed.
Filled with year when the minute of audit refusal was signed.
Filled with number of the SP2.
Filled with date of the SP2.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with name of the Taxpayer or the Taxpayers representative
or the Taxpayers proxy.
Filled with occupation/position of the Taxpayer or the Taxpayers
representative or the Taxpayers proxy.
Filled with address of the Taxpayer or the Taxpayers
representative or the Taxpayers proxy.
Filled with signature, name, and NIP of the Tax Auditor Team
Supervisor.
Filled with signature, name, and NIP of the Tax Auditor Team
leader.
Filled with signature, name, and NIP of the Tax Auditor Team
member.
Filled with position name of the head of Audit Executor Unit.
Filled with signature, name, and NIP, and position stamp of the
head of Audit Executor Unit.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5C.

FORMAT OF STATEMENT
SMOOTHNESS OF AUDIT:

LETTER

OF

REFUSAL

TO

ASSIST

THE

STATEMENT LETTER OF REFUSAL TO ASSIST THE SMOOTHNESS OF AUDIT


I, the undersigned below:
Name
: .. (1)
Occupation/Position
: .. (2)
Address
: .. (3)
In this case acting as ........ (4) of the Taxpayer:
Name
: .
(5)
TIN
:
(6)
Address
: .
(7)
In connection with the Audit by the Tax Auditor from the Directorate General of
Tax:
Number
Name/NIP
Rank / Class
Position

(8)

(9)

(10)

(11)

Pursuant to Tax Audit Warrant number (12) date .


(13) hereby certifies refusing the Audit with the reason of . (14)
In witness whereof this statement letter of refusal to assist the smoothness
of Audit is made and signed with full consciousness and without coercion from
whosoever, and we are ready to be responsible for all legal consequences arising
from this statement.
..,

.
(

15)
Who
makes
statement,

the

Stamp
duty
IDR 6.000

.
16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6FILLING INSTRUCTION OF STATEMENT LETTER OF REFUSAL TO ASSIST THE


SMOOTHNESS OF AUDIT
Number (1)

Number (2)

Number (3)

Number (4)

Number
Number
Number
Number
Number
Number
Number

:
:
:
:
:
:
:

(5)
(6)
(7)
(8)
(9)
(10)
(11)

Number (12) :
Number (13) :
Number (14) :
Number (15) :
Number (16) :

Filled with name of employee/family of the Taxpayer or the party


who represents the Taxpayer who signs the statement letter of
refusal to assist the smoothness of Audit.
Filled with occupation/position of employee of the Taxpayer or the
party who represents the Taxpayer who signs the statement letter
of refusal to assist the smoothness Audit.
Filled with address of employee/family of the Taxpayer or the
party who represents the Taxpayer who signs the statement letter
of refusal to assist the smoothness Audit.
Filled with the position of employee/family of the Taxpayer or the
party who represents the Taxpayer who signs the statement letter
of refusal to assist the smoothness Audit.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with sequence number.
Filled with name and NIP of the Tax Auditor team.
Filled with rank/class of the Tax Auditor team
Filled with position in the Tax Auditor team, which are
supervisor, team leader, team member
Filled with number of the SP2
Filled with date of the SP2
Filled with the reason for the refusal to assist the smoothness of
Audit.
Filled with location and date when the statement letter is made.
Filled with signature and name of employee/family of the
Taxpayer or the party who represents the Taxpayer who signs the
statement letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7D.

MINUTE OF REFUSAL TO ASSIST THE SMOOTHNESS OF AUDIT:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)
MINUTE OF REFUSAL TO ASSIST THE SMOOTHNESS OF AUDIT

On this day . (2) date (3) month .. (4) year


.. (5) pursuant to the Tax Audit Warrant number . (6) date
(7), then we are mentioned below as a Tax Auditor team who are assigned
to perform Audit to the Taxpayer:
Name
: ..
(8)
TIN
:
(9)
Address
:
..
(10)
that in connection with the Audit, the employee/family member of The Taxpayer in
this matter is represented by:
Name
:

(11)
Occupation/Position
:

(12)
Address
:

(13)
has refused to make and sign statement letter of refusal to assist the smoothness
of Audit.
In witness whereof this minute of the refusal to assist the smoothness audit
is made truthfully under the oath of office, then it is closed and signed by the Tax
Auditor team.
Tax Auditor Team:
Supervisor,
..
NIP (14)
Acknowledged by:
(17)
...

Team Leader,
..
NIP ..

(15)
NIP (18)
Team member,

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8-

.
NIP . (16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-9FILLING INSTRUCTION OF THE MINUTE OF REFUSAL


TO ASSIST THE SMOOTHNESS AUDIT
Number (1)
Number (2)

:
:

Number (3)

Number (4)

Number (5)

Number
Number
Number
Number
Number
Number

:
:
:
:
:
:

(6)
(7)
(8)
(9)
(10)
(11)

Number (12) :
Number (13) :
Number (14) :
Number (15) :
Number (16) :
Number (17) :
Number (18) :

Filled with letterhead.


Filled with the day when the minute of the refusal to assist the
smoothness of audit is signed.
Filled with date when the minute of the refusal to assist the
smoothness of audit is signed.
Filled with month when the acknowledgement of the refusal to
assist the smoothness audit is signed.
Filled with year when the minute of the refusal to assist the audit
smoothness was signed.
Filled with number of the SP2.
Filled with date of the SP2.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with name of employee/family member of the Taxpayer who
refuses to assist the smoothness of audit.
Filled with position of employee/family member of the Taxpayer
who refuses to assist the smoothness of audit.
Filled with address of employee/family member of the Taxpayer
who refuses to assist the smoothness audit.
Filled with signature, name, and NIP of the Tax Auditor Team
Supervisor.
Filled with signature, name, and NIP of the Tax Auditor Team
leader.
Filled with signature, name, and NIP of the Tax Auditor Team
member.
Filled with position name of the head of Audit Executor Unit.
Filled with signature, name, and NIP, and position stamp of the
head of Audit Executor Unit.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 10 E.

FORMAT OF THE MINUTE OF NON-FULFILLING THE SUMMON FOR


OFFICE AUDIT:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)

THE MINUTE OF NON-FULFILLING THE SUMMON FOR OFFICE AUDIT


On this day . (2) date (3) month .. (4) year .
(5), location .. (6), pursuant to Tax Audit Warrant number .
(7) date (8), we:
NUMBER
NAME /NIP
RANK / CLASS
POSITION
(9)
(10)
(11)
(12)
who are assigned to perform the Office Audit against the Taxpayer:
Name

: ..

(13)

TIN
Address

:
: ..

(14)
(15)

Period and Fiscal Year


:
(16)
has sent the Summons Letter for Office Audit to the Taxpayer number
(17) date . (18), but the Taxpayer does not attend to fulfill the summon
within the predetermined time.
In witness whereof this minute of non-fulfilling the summon for audit is
made truthfully on power of the oath of office, then it is closed and signed by the
Tax Auditor Team.
Tax Auditor Team:
Supervisor,

NIP
9)
Acknowledged by:
(22)

(20)
NIP (23)

Team Leader,

NIP
Team member,

(1

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 11 -

(21)

NIP

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 12 FILLING INSTRUCTION OF THE MINUTE OF NON-FULFILLING THE SUMMON


FOR OFFICE AUDIT
Number (1)
Number (2)

:
:

Number (3)

Number (4)

Number (5)

Number (6)

Number
Number
Number
Number
Number
Number
Number
Number
Number
Number

:
:
:
:
:
:
:
:
:
:

(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)

Filled with letterhead.


Filled with the day when the minute of non-fulfilling the summon
for office audit is signed.
Filled with the date the minute of non-fulfilling the summon for
office audit is signed..
Filled with the month when the minute of non-fulfilling the
summon for office audit is signed..
Filled with the year when the minute of non-fulfilling the summon
for office audit is signed..
Filled with the location when the minute of non-fulfilling the
summon for office audit is signed..
Filled with number of SP2.
Filled with date of SP2.
Filled with sequence number.
Filled with name and NIP of the Tax Auditor Team.
Filled with rank and class of the Tax Auditor Team.
Filled with position of the Tax Auditor Team.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with Filled with Tax Period and Fiscal Year to be audited
Example:
1.

Number (17) :
Number (18) :
Number (19) :
Number (20) :

The Audit was performed for Tax Period of January to May of


2001, then it will be filled:
0 1 1 1
0 5 1 1
2. The Audit was performed for Fiscal Year of 2011 and the
accounting year is the same with calendar year, then it will be
filled:
0 1 1 1
1 2 1 1
3. The Audit was performed for Fiscal Year of 2011, but the
accounting year commencing from April 1, 2011 until March
31, 2012, then it will be filled:
0 4 1 1
0 3 1 2
Filled with number of the minute of Non-Fulfilling the Summons
for Office Audit.
Filled with the date of the minute of Non-Fulfilling the Summons
for Office Audit.
Filled with signature, name and NIP of the Tax Auditor team
supervisor.
Filled with signature, name and NIP of the Tax Auditor team
leader.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 13 Number (21) :
Number (22) :
Number (23) :

Filled with signature, name and NIP of the Tax Auditor team
member.
Filled with position name of the head of Audit Executor Unit.
Filled with signature, name and NIP of the Supervisor and stamp
of the Audit Executor Unit.

Copy as its
original version
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION
OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
MARTOWARDOJO

MINISTER OF FINANCE OF
THE
REPUBLIC OF INDONESIA
Signed

AGUS D.W.

APPENDIX VI
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

A.

FORMAT OF SUMMON FOR PROVIDING THE INFORMATION


Ministry
of finance
logo

Number
(3)
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)
: . (2)

.., ..

: Immediately
:: First/ second Summons*)
For Providing the Information

..
.. (4)
Dear Sir/ Madam,
As the implementation of the Regulation of The Minister of Finance
Number
/PMK.03/
concerning Audit Procedure and in connection with the
books, records, and documents that has been borrowed to the Tax Auditor team
pursuant to the Tax Audit Warrant Number .. (5) dated
(6), hereby your presence is required at:
Day/ Date : ..
(7)
Time
: ..
(8)
Venue
: ..
(9)
to provide information/explanation to the Tax Auditor team.
Thank you for taking this into consideration.

Received by
Position
Date
Signature/ stamp

:
:
:
:

(12)
(13)
(14)
(15)

Yours Faithfully
.
(10)

....
NIP .
(11)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2FILLING INSTRUCTION OF SUMMONS FOR PROVIDE INFORMATION


Number
Number
Number
Number

(1)
(2)
(3)
(4)

:
:
:
:

Number (5)
Number (6)
Number (7)

:
:
:

Number (8)

Number (9)

Number (10)
Number (11)

:
:

Number (12)

Number (13)

Number (14)

Number (15)

Annotation *)

Filled with letterhead.


Filled with letter number
Filled with location and date when the letter is signed.
Filled with name and address of the Taxpayer that will be
requested for information.
Filled with number of SP2.
Filled with date of SP2.
Filled with the day/date when the Taxpayer requested to be
present for provide information.
Filled with time of day when the Taxpayer is requested to be
present for providing the information.
Filled with the meeting location where the Taxpayer requested
to be present for providing the information.
Filled with position name of the head of Audit executor unit.
Filled with signature, name, NIP and position stamp of the
head of Audit executor unit.
Filled with name of a person who received the first summon or
the second summon to provide information.
Filled with position of a person who receives the first summon
or the second summon to provide information.
Filled with the date when the first summon or the second
summon to provide information is received.
Filled with signature of a person or company stamp that
received the first summon or the second summon to provide
information.
Filled with appropriate choice.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3B.

FORMAT OF MINUTE OF THE PROVISION OF INFORMATION BY TAXPAYER


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)
MINUTE OF THE PROVIISON OF INFORMATION BY TAXPAYER

On this day date . month (2) located


in (3), we are as Tax Auditor team from the Directorate General of
Tax:
NAME/NIP

RANK/CLASS

POSITION

(4)

(5)

(6)

Pursuant to Tax Audit Warrant Number: .. (7) dated . (8)


has asked for information in accordance with the summon number:
.. (9) dated . (10), to :
Name
: ..
(11)
Occupation/Position
: ..
(12)
Address
: ..
(13)
In this case acting as:
Taxpayer
Representative
Proxy
(14)
of the Taxpayer:
Name
: (15)
TIN

(16)
Address
: ... (17)
with the description/explanation as follows:

.. (18)
In witness whereof this minute is made in truthfully and signed by:
Tax Auditor Team:

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4Taxpayer/Representative/Proxy *)

(22)
(19)
Acknowledged by:
(23)

Supervisor,

.
NIP

Team Leader,

..
NIP ..

(20)
NIP (24)

Team member,

..

NIP .. (21)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5FILLING INSTRUCTION OF MINUTE OF


THE PROVISION OF INFORMATION BY TAXPAYER
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)

:
:
:
:
:
:

Number
Number
Number
Number
Number

(7)
(8)
(9)
(10)
(11)

:
:
:
:
:

Number (12) :
Number (13) :
Number
Number
Number
Number
Number

(14)
(15)
(16)
(17)
(18)

:
:
:
:
:

Number
Number
Number
Number

(19)
(20)
(21)
(22)

:
:
:
:

Annotation *) :
Number (23) :
Number (24) :

Filled with letterhead.


Filled with day, date, month and year when the minute is made.
Filled with location where the acknowledgement was made.
Filled with name and NIP of the Tax Auditor.
Filled with rank and class of the Tax Auditor.
Filled with position in Tax Auditor Team, which is supervisor,
team leader, or team member.
Filled with number of the SP2.
Filled with date of the SP2.
Filled with the summons letter number.
Filled with date of the summons letter
Filled with name of the Taxpayer, Taxpayers representative, or
the Taxpayers proxy who signs the minute.
Filled with occupation/position of the audited Taxpayer,
Taxpayers representative, or the Taxpayers proxy.
Filled with the address of the audited Taxpayer, Taxpayers
representative, or the Taxpayers proxy.
Filled with marking [ ] in the appropriate box.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with information/explanation that has been given by the
Taxpayer/Representative/Proxy. In case of the blank field is
insufficient could be made a separated attachment signed by the
mentioned parties in this minute.
Filled with signature, name and NIP of the Auditor supervisor.
Filled with signature, name and NIP of the Auditor team leader.
Filled with signature, name and NIP of the Auditor team member.
Filled
with
signature,
name
of
the
Taxpayer/Representative/Proxy.
Filled with appropriate choice.
Filled with position name of the head of Audit Executor unit.

Filled with signature, name, NIP, and position stamp of the head
of Audit Executor unit.
Copy as its
MINISTER OF FINANCE OF THE
original version
REPUBLIC OF INDONESIA
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF MINISTRY ADMINSTRATION SECTION
Signed
Signed and stamped.
GIARTO

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6NIP 195904201984021001
MARTOWARDOJO

AGUS D.W.

APPENDIX VII
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

FORMAT OF NOTIFICATION OF TAX AUDIT FINDING, NOTIFICATION OF TAX


AUDIT FINDING DUE TO THE TAXABLE INCOME IS CALCULATED IN EX
OFFICIO AND LIST OF AUDIT:
A1. FORMAT OF NOTIFICATION OF TAX AUDIT FINDING:
Ministry
of finance
logo

Number
(3)
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
: (2)

: Highly Immediately
: (4)
: Notification of tax audit findings

.
. (5)
Dear Sir/ Madam,
In connection with the Tax Audit Warrant number (6)
herewith presented the Audit result as attached.
Considering the Audit result is connected with the tax obligation that you
should be fulfilled, then an invitation to perform the Audit result final discussion.
you will be delivered.
If you do not provide a written response on the Audit result and not attend
in the Audit result final discussion in accordance within the determined time
period; consequence, the Audit result shall be deemed fully approved by you and
the Audit result final discussion is deemed have been performed and your tax
obligation will be calculated in accordance with the Audit result.
In witness whereof, thank you for your cooperation and taking it into your
consideration and cooperation.
Yours Faithfully
.
(8
)
Received by
Position
Date
Signature/ stamp

: ..
: ..
: ..
: ..

(10)
(11)
(12)
(13)

.
NIP..
(9
)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2FILLING INSTRUCTION OF NOTIFICATION OF TAX AUDIT FINDING.


Number (1)
Number (2)
Number (3)

:
:
:

Number
Number
Number
Number
Number
Number

:
:
:
:
:
:

(4)
(5)
(6)
(7)
(8)
(9)

Number (10)

Number (11)

Number (12)

Number (13)

Filled with letterhead.


Filled with number of The Notification of tax audit findings.
Filled with location and date when the Notification of tax audit
findings was signed.
Filled with number of attached documents.
Filled with name and address of the audited Taxpayer.
Filled with number of the Tax Audit Order letter.
Filled with the date of the Tax Audit Order letter.
Filled with position name of the official who signs the letter.
Filled with signature, name, NIP, and position stamp of the
official who was signed the letter.
Filled with name of a person who receives the Notification of tax
audit findings.
Filled with position of a person who receives the Notification of
tax audit findings.
Filled with date when the Notification of tax audit findings is
received.
Filled with signature of a person and company stamp who
received the Notification of tax audit findings.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3A2. FORMAT OF NOTIFICATION OF TAX AUDIT FINDINGS DUE TO THE TAXABLE


INCOME IS CALCULATED IN EX OFFICIO:
Ministry
of finance
logo

Number
(3)
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
: . (2)

, .

: Highly Immediately
: . (4)
: Notification of tax audit findings (due to taxable income
is calculated in ex officio)

(5)
Dear Sir/ Madam,
In connection with the Tax Audit Warrant number (6) dated
(7) it is herewith presented the Audit result as attached. The Audit
Result is calculated in ex officio due to . (8) so the amount of the taxable
income cannot be calculated.
You could deliver written response within the maximum period of 7 (seven)
working days since this letter is received, in the form of:
a. Audit Result Approval Statement Sheet, in the event that you agree to all the
Audit results; or
b. Refutation Letter of which is accompanied with the reason that supporting the
refutation, in the event that you dont agree in part or all of the Audit result.
In the event that you could not deliver the written response within
predetermined time as mentioned above:
a. You could extend the response delivery within the maximum period of 3 (three)
working days after the predetermined time of 7 (seven) working days ends.
b. The concerned Extension time could be performed by firstly submitting a
Notification Letter of Time Period Extension of Audit Result Response
Submission before the predetermined time of 7 (seven) working days end.
Considering the Audit result is connected with the tax obligation of which
you should fulfilled, after you have deliver the written response, an invitation to
perform the Audit result final discussion will be delivered to you.
Due to within the Audit, the calculation is performed in ex officio, as result
the documents that could be considered in the final discussion shall be limited to:
a. documents associated to the gross income for the calculation the net income tax
in ex officio; and
b. tax credit document as a deduction of Income Tax.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4Should you do not provide the written response on the Audit result and do
not attend in the Audit result final discussion in accordance with the
predetermined time, as result the Audit result shall be deemed fully approved by
you and the Audit result final discussion shall be deemed to have been performed
and your tax obligation will be calculated in accordance with the Audit result.
In witness whereof it is conveyed, thank you for your cooperation and taking
it into your consideration.
Yours Faithfully
(9)

Received by
Position
Date
Signature/ stamp

: (11)
: (12)
: .. (13)
: .. (14)

NIP.(10)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5FILLING INSTRUCTION OF NOTIFICATION OF TAX AUDIT FINDINGS (DUE TO


THE TAXABLE INCOME IS CALCULATED IN EX OFFICIO)
Number (1) :
Number (2) :
Number (3) :
Number
Number
Number
Number
Number

(4)
(5)
(6)
(7)
(8)

:
:
:
:
:

Number (9) :
Number (10) :
Number (11) :
Number (12) :
Number (13) :
Number (14) :

Filled with letterhead.


Filled with number of The Notification of tax audit findings.
Filled with location and date when the Notification of tax audit
findings was signed.
Filled with number of attached documents.
Filled with name and address of the audited Taxpayer.
Filled with number of the Tax Audit Order letter.
Filled with the date of the Tax Audit Order letter.
Filled with the reason of being performing ex officio taxable income.
Example: because the Taxpayer does not give books, records,
and/or documents of which are required or the Taxpayer refuses to
be audited that is evidenced with the presence of Audit refusal
statement letter.
Filled with position name of the official who signs the letter.
Filled with signature, name, NIP, and position stamp of the official
who signs the letter.
Filled with name of a person who receives the Notification of tax
audit finding.
Filled with position of a person who receives the Notification of tax
audit finding.
Filled with date when the Notification of tax audit findings is
received.
Filled with signature of a person and company stamp who receives
the Notification of tax audit finding.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6A3.

FORMAT OF AUDIT FINDINGS LIST:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)
AUDIT FINDINGS LIST
Tax Period and Fiscal Year: .. (2)

Number

Corrected Posts

Amount of
Correction

Basis of
Performing a
correction

(3)

(4)

(5)

(6)

.., (7)
Tax Auditor Team:
Supervisor,

NIP
(10)
Acknowledged by:
(8)

Team Leader,

..

NIP ..

(11)
NIP (9)
Team member,

..

NIP .. (12)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7FILLING INSTRUCTION OF AUDIT FINDINGS LIST


Number (1)
Number (2)

:
:

Number (3)
Number (4)

:
:

Number (5)
Number (6)
Number (7)

:
:
:

Number (8)
Number (9)

:
:

Number (10) :
Number (11) :
Number (12) :

Filled with letterhead.


Filled with Tax Period and Fiscal Year in accordance with the Tax
Audit Order Letter.
Filled with sequence number.
Filled with corrected posts in accordance with in the financial
report/SPT of the audited Taxpayer, including correction on the
Tax Underpayment calculation.
Filled with amount of correction found.
Filled with basis of correction as well as its explanation.
Filled with location, date, month, and year when the Audit
Findings List is made.
Filled with position name of the head of Audit executor unit.
Filled with Filled with signature, name, NIP, and position stamp
of the head of Audit executor unit.
Filled with signature, name and NIP of the Tax Auditor Team
Supervisor.
Filled with signature, name and NIP of the Tax Auditor Team
leader.
Filled with signature, name and NIP of the Tax Auditor Team
member.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8B.
B1.

FORMAT OF STATEMENT LETTER OF REFUSAL TO RECEIVE SPHP AND


MINUTE OF REFUSAL TO RECEIVE SPHP:
FORMAT OF STATEMENT LETTER OF REFUSAL TO RECEIVE SPHP:
STATEMENT LETTER OF
REFUSAL TO RECEIVE THE AUDIT RESULT NOTIFICATION LETTER/
AUDIT RESULT FINAL DISCUSSION INVITATION/
SUMMONS TO SIGN THE MINUTE
OF THE AUDIT RESULT FINAL DISCUSSION *)

I, the undersigned below:


Name
: .
Occupation/Position
: .
Address
: .
In this case acted as:
Taxpayer
Representative

Proxy

(1)
(2)
(3)

(4)

of the Taxpayer:
Name
: .. (5)
TIN
Address

:
(6)
: .. (7)

who is under audited based on the Tax Audit Warrant number .. (8)
dated (9) hereby certifies refusing to receive (10) with
the reason .. (11)
In witness whereof this refusal statement letter is made and signed in full
consciousness and without coercion from whoseover, and I am ready to be
responsible for all legal consequences arising from this statement.
.,. (12)
Who make the statement,
Duty
Stamp IDR
6.000
(13)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-9FILLING INSTRUCTION OF
STATEMENT LETTER OF
REFUSAL TO RECEIVE THE AUDIT RESULT NOTIFICATION LETTER/
AUDIT RESULT FINAL DISCUSSION INVITATION/
SUMMONS TO SIGN THE MINUTE
OF THE AUDIT RESULT FINAL DISCUSSION
Number (1)
Number (2)
Number (3)
Number (4)
Number (5)
Number (6)
Number
Number
Number
Number

(7)
(8)
(9)
(10)

Number (11)
Number (12)
Number (13)
Annotation *)

: Filled with name of the Taxpayer, Taxpayers representative,


or Taxpayers proxy who signs the refusal statement letter.
: Filled with occupation/position of the Taxpayer, Taxpayers
representatives, or Taxpayers proxy who signs the refusal
statement letter.
: Filled with the address of the Taxpayer, Taxpayers
representatives, or Taxpayers proxy who signs the refusal
statement letter.
: Filled with [ ] sign in the required box.
: Filled with name of the audited Taxpayer.
: Filled with Tax Identification Number of the audited
Taxpayer.
: Filled with the address of the audited Taxpayer.
: Filled with number of The Audit Order Letter.
: Filled with the date of The Audit Order Letter.
: Filled with type of letter that is refused by the Taxpayer to
receive.
: Filled with reason of the refusal to receive the letter.
: Filled with location, date, month, and year of the refusal
statement letter.
: Filled with signature and name of the Taxpayer, Taxpayers
representative, or the Taxpayers proxy who sign the Refusal
Statement Letter to receive the letter.
: Filled by cross out which are not needed.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 10 B2. FORMAT OF THE MINUTE OF REFUSAL TO RECEIVE SPHP:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)

MINUTE OF REFUSAL TO RECEIVE THE AUDIT RESULT NOTIFICATION LETTER


(SPHP)
On this day . (2) date (3) month .. (4) year ..
(5) pursuant to the Tax Audit Warrant number . (6) date (7),
we who are mentioned below:
Number
Name /NIP
Rank / Class
Position

(8)

(9)

(10)

(11)

has met to:


Name
: (12)
Occupation : (13)
Address
: (14)
In this case acted as:
Taxpayer
Representative

Proxy

(15)

of the Taxpayer:
Name
: . (16)
TIN
Address

:
(17)
: . (18)

to deliver directly the SPHP, in this matter the Taxpayer/ Representative/ Proxy*)
refuses to receive SPHP and refuses to sign the refusal letter to receive the SPHP.
In witness whereof this minute is made in truthfully upon power of the oath
of office, then it is closed and signed by the Tax Auditor team.
Tax Auditor Team:
Supervisor,

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 11
NIP
1)
Acknowledged by:

Team Leader,

(19)

(22) NIP

NIP
(20)

Team member,

NIP

(23)

(2

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 12 FILLING INSTRUCTION OF THE MINUTE OF REFUSAL TO RECEIVE THE AUDIT


RESULT NOTIFICATION LETTER
Number (1)
Number (2)
Number (3)
Number (4)
Number (5)
Number
Number
Number
Number
Number
Number

(6)
(7)
(8)
(9)
(10)
(11)

Number (12)
Number (13)
Number (14)
Number
Number
Number
Number
Number
Number

(15)
(16)
(17)
(18)
(19)
(20)

Number (21)
Number (22)
Number (23)

: Filled with letterhead.


: Filled with day when the minute of the refusal to receive SPHP is
signed.
: Filled with date when the minute of the refusal to receive the SPHP
is signed.
: Filled with month when the acknowledgement of the refusal to
receive the SPHP is signed.
: Filled with year when the minute of the refusal to receive the SPHP
is signed.
: Filled with number of the SP2.
: Filled with date of the SP2.
: Filled with sequence number.
: Filled with name and NIP of the Tax Auditor.
: Filled with rank and class of the Tax Auditor.
: Filled with position in the Tax Auditor team, which are
supervisor, team leader, or team member.
: Filled with name of the Taxpayer/ Taxpayers Representative/
Power of Taxpayer or other parties who was met when the SPHP
submission.
: Filled with occupation of the Taxpayer/ Taxpayers Representative/
Taxpayer proxy or other party who meets when the SPHP is
submitted.
: Filled with the address of the Taxpayer/ Taxpayers Representative/
Power of Taxpayer or other parties who was met when the SPHP
submission.
: Filled with [ ] sign in appropriate box.
: Filled with name of the audited Taxpayer.
: Filled with Tax Identification Number of the audited Taxpayer.
: Filled with the address of the audited Taxpayer.
: Filled with position name of the head of Audit executor unit.
: Filled with signature, name, NIP, and position stamp of the head of
Audit executor unit.
: Filled with signature, name and NIP of the Tax Auditor Team
Supervisor.
: Filled with signature, name and NIP of the Tax Auditor team leader.
: Filled with signature, name and NIP of the Tax Auditor team
member.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 13 C. FORMAT OF STATEMENT SHEET OF THE AUDIT RESULT APPROVAL:


STATEMENT OF THE AUDIT RESULT APPROVAL
In connection with the Audit Result Notification Letter number ..
(1) date .. (2), hereby I:
Name
: .. (3)
Occupation : .. (4)
Address
: .. (5)
In this case acted as:
Taxpayer

Representative

Proxy

(6)

of the Taxpayer:
Name
: ..

(7)

TIN
Address

(8)
(9)

:
: ..

hereby certifies in truthfully, approve all the Audit result.


In witness whereof this approval statement sheet is made and signed to be
used appropriately.

, .. (10)
Who make the statement
Stamp
Duty
IDR 6.000

(11)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 14 FILLING INSTRUCTION OF STATEMENT OF THE AUDIT RESULT APPROVAL


Number (1) :
Number (2) :
Number (3) :
Number (4) :
Number (5) :
Number
Number
Number
Number
Number

(6) :
(7) :
(8) :
(9) :
(10) :

Number (11) :

Filled with number of the Audit Result Notification Letter.


Filled with date of the Audit Result Notification Letter.
Filled with name of the Taxpayer, Taxpayers Representative, or
Power of Taxpayer who was signed the Statement Sheet of Audit
Result Approval.
Filled with occupation/position of the Taxpayer, Taxpayers
Representative, or Taxpayers proxy who signs the Statement Sheet
of Audit Result Approval.
Filled with the address of the Taxpayer, Taxpayers Representative,
or Taxpayers proxy who signs the Statement Sheet of Audit Result
Approval.
Filled by marking [ ] in the required box.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with location, date, month, and year when the statement
letter is made.
Filled with signature and name of Taxpayer/ Representative/
Proxy.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 15 D.

FORMAT OF NOTIFICATION OF TAX AUDIT FINDINGS RESPONSES


SUBMISSION PERIOD EXTENSION:

Head of

(1)
Dear Sir/ Madam
In connection with the Audit Result Notification Letter number
.. (2) date .. (3), hereby I:
Name
: .
Occupation : .
Address
: .

(4)
(5)
(6)

In this case acted as:


Taxpayer;
of the Taxpayer:

(7)

Representative;

Proxy

Name

(8)

TIN
Address

:
:

(9)
(10)

by filing the time period extension of the Audit result response submission until the
time limit, which is specified in accordance with the applicable provisions.
In witness whereof this application letter is delivered, and thank you for your
kind attention.
Yours Faithfully
.., .
(11)

.
(12)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 16 FILLING INSTRUCTION NOTIFICATION OF TAX AUDIT FINDINGS RESPONSES


SUBMISSION PERIOD EXTENSION
Number
Number
Number
Number

(1)
(2)
(3)
(4)

:
:
:
:

Number (5) :
Number (6) :
Number
Number
Number
Number
Number

(7) :
(8) :
(9) :
(10) :
(11) :

Number (12) :

Filled with name and address of the Audit executor unit.


Filled with number of the SPHP.
Filled with date of the SPHP.
Filled with name of the Taxpayer, Taxpayers Representative, or
Taxpayers proxy who signs the Statement Sheet of Audit Result
Approval.
Filled with occupation/position of the Taxpayer, Taxpayers
Representative, or Taxpayers proxy who signs the Statement Sheet
of Audit Result Approval.
Filled with the address of the Taxpayer, Taxpayers Representative,
or Taxpayers proxy who signs the Statement Sheet of Audit Result
Approval.
Filled by marking [ ] in the required box.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with location, date, month, and year when the application
letter was made.
Filled with signature and name of Taxpayer/ Representative/ Proxy.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 17 E.

FORMAT OF THE MINUTE OF NON-SUBMISSION WRITTEN RESPONSE


AGAINST SPHP:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
THE MINUTE OF NON-SUBMISSION
WRITTEN RESPONSE AGAINST SPHP

On this day . (2) date (3) month .. (4) year


.. (5) located in (6) pursuant to the Tax Audit Warrant number
. (7) date (8), we who are mentioned below:
Number
Name/NIP
Rank/Class
Position
(9)
(10)
(11)
(12)
who was assigned to perform Audit to the Taxpayer:
Name
: (13)
TIN
Address

:
(14)
: (15)

Tax Period and Fiscal Year :


(16)
has provided an opportunity to the Taxpayer to submit written response in
accordance with the Audit Result Notification Letter number .. (17) date
.. (18), but the Taxpayer does not give written response within the
specified time.
In witness whereof this minute is made truthfully upon power of the oath of
office, then it is closed and signed by the Tax Auditor team.
Tax Auditor Team:
Supervisor,

Acknowledged by:
(19)

(22)
NIP (20)

..
NIP ..
(21)
Team Leader,
..
NIP ..
Team member,
..
NIP

.. (23)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 18 FILLING INSTRUCTION OF THE MINUTE OF NON-SUBMISSION


AWRITTEN RESPONSE AGAINST SPHP
Number (1)
Number (2)
Number (3)
Number (4)
Number (5)
Number (6)
Number
Number
Number
Number
Number
Number

(7)
(8)
(9)
(10)
(11)
(12)

Number
Number
Number
Number
Number
Number
Number
Number

(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)

Number (21)
Number (22)
Number (23)

: Filled with letterhead.


: Filled with day when the minute of non-submission written
response oagainst SPHP is signed.
: Filled with date when the minute of non-submission written
response against SPHP is signed.
: Filled with month when the minute of non-submission written
response oagainst SPHP is signed.
: Filled with year when the minute of non-submission written
response against SPHP is signed.
: Filled with location in which the minute of non-submission written
response against SPHP is signed .
: Filled with number of the SP2.
: Filled with date of the SP2.
: Filled with sequence number.
: Filled with name and NIP of the Tax Auditor.
: Filled with rank and class of the Tax Auditor
: Filled with position in the Tax Auditor team, which are
supervisor, team leader, team member
: Filled with name of the audited Taxpayer.
: Filled with Tax Identification Number of the audited Taxpayer.
: Filled with the address of the audited Taxpayer.
: Filled with the audited Tax Period and Fiscal Year.
: Filled with number of the SPHP.
: Filled with date of the SPHP.
: Filled with position name of the head of Audit executor unit.
: Filled with signature, name, NIP, and position stamp of the official
who signs the minute.
: Filled with signature, name, and NIP of the Tax Auditor team
supervisor.
: Filled with signature, name, and NIP of the Tax Auditor team
leader.
: Filled with signature, name, and NIP of the Tax Auditor team
member.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 19 F.

FORMAT OF AUDIT RESULT FINAL DISCUSSION INVITATION LETTER


Ministry
of finance
logo

Number
(3)
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
: (2)

, ..

: Immediately
:: Audit Result Final Discussion Invitation

(4)
Dear Sir/ Madam,
In connection with the Audit Result Notification Letter number .. (5)
date (6), which has been delivered to you on the date of (7),
hereby we invite you on:
Day/Date
: (8)
Time
: (9)
Venue
: (10)
to perform the Audit Result Final Discussion on the Audit result, which has been
delivered to you.
Should you do not attend in the Audit result final discussion in accordance
with the day and date mentioned above then the Audit result final discussion shall
be deemed have been performed.
In witness whereof the invitation is made, thank you for your cooperation.
Yours Faithfully,
..
)
Received by
Position
Date
Signature/ stamp

:
:
:
: ..

(13)
(14)
(15)
(16)

(11

..
NIP
(12
)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 20 FILLING INSTRUCTION OF
AUDIT RESULT FINAL DISCUSSION INVITATION LETTER
Number (1)
Number (2)
Number (3)
Number
Number
Number
Number
Number
Number
Number
Number
Number

(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)

Number (13)
Number (14)
Number (15)
Number (16)

: Filled with letterhead.


: Filled with number of the Audit Result Final Discussion invitation
letter
: Filled with location and date of the Audit Result Final Discussion
invitation letter.
: Filled with name and address of the Taxpayer.
: Filled with number of the SPHP.
: Filled with date of the SPHP.
: Filled with date when the SPHP is delivered to the Taxpayer.
: Filled with day and date of the Audit Result Final Discussion.
: Filled with time when the Audit Result Final Discussion is held.
: Filled with location where the Audit Result Final Discussion is held.
: Filled with position name of the official who was signed the letter.
: Filled with signature, name, NIP, and position stamp of the official
who signs the
: Filled with name of a person who receives the Audit Result Final
Discussion invitation letter.
: Filled with position of a person who receives the Audit Result Final
Discussion invitation letter.
: Filled with the date when the Audit Result Final Discussion
invitation letter is received.
: Filled with signature of a person and stamp of the company who
receives the Audit Result Final Discussion invitation letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 21 G.

FORMAT OF THE TREATISE OF DISCUSSION:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAXATION
(1)
THE TREATISE OF DISCUSSION

SP2 Number
Name of Taxpayer
TIN
Address

: date
(2)
: ..
(3)
:
(4)
: ..
(5)

Tax Period and Fiscal Year :


(6)
1. Principal Correction Problem
.
.
(7)
a. Basic Tax Auditor Corrections listed in SPHP
..
..
(8)
b. Taxpayer response on SPHP
..
..
(9)
c. Tax Auditor opinion in the Final Discussion
...
(10)
d. Taxpayer opinion in the Final Discussion
...
(11)
2. Principal Correction Problems
.
.(7)
a. Tax Auditor Corrections Basis Based on SPHP
..
..(8)
b. Taxpayer response on SPHP
..
..(9)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 22 c. Tax Auditor opinion in the Final Discussion


...
(10)
d. Taxpayer opinion in the Final Discussion
...
e.
(11)
3. And so on.
4. Audit Result Conclusion:
Number

Corrected Posts

Correction
conform
with SPHP

Correction
conform with
Taxpayer
Response

(12)

(13)

(14)

(15)

Correction Conform
with Audit
Conform
Conform
with Audit
with
Taxpayer
(16)

(17)

Based on the Audit result final discussion as listed in this treatise of


the discussion, the Taxpayer apply / does not apply*) the discussion with the Audit
Quality Assurance Team.

(18)
Taxpayer/Representative/Proxy*)

.. (19)

.,
Tax Auditor Team:
Supervisor,

NIP
(22)
Acknowledged by:
. (20)

Team Leader,

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 23 -

(23)
NIP . (21)

NIP
Team member,

..
(24)
*) strech up unnecessary

NIP ..

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 24 FILLING INSTRUCTION OF THE TREATISE OF DISCUSSION


Number
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)
(7)

:
:
:
:
:
:
:

Number (8)

Number (9)

Number (10) :

Filled with letterhead.


Filled with number and date of the SP2.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with the audited Tax Period and Fiscal Year.
Filled with corrected item, the amount according the Tax return,
the amount according the Tax Auditor and the correction value.
Filled with basic/explanation of correction performed according to
the Tax Auditor including its legal basis as listed in the SPHP.
1. In terms of the Taxpayer submit a written response on the
SPHP, it shall be filled with the Taxpayer response as listed in
the written response.
2. In terms of the Taxpayer does not submit the written response
on the SPHP but attending the Final Discussion, it shall be
filled with the response that presented by the Taxpayer in the
Audit Result Final Discussion.
3. In terms of the Taxpayer does not submit the written response
on the SPHP and does not attend the Audit Result Final
Discussion, it shall be filled with description that the Taxpayer
does not submit a written response and does not attend in the
Audit Result Final Discussion.
1. In terms of the Taxpayer submit written response either they
attend or does not attend the Audit Result Final Discussion, it
shall befilled with opinion of the Tax Auditor on the written
response or on the response that presented by the Taxpayer in
the Audit Result Final Discussion.
2. In terms of the Taxpayer didnt submit the written response on
the SPHP but present in the Audit Result Final Discussion, it
shall be filled with the response that presented by the Taxpayer
in the Audit Result Final Discussion.
3. In terms of the Taxpayer didnt submit the written response on
the SPHP and didnt attend in the Audit Result Final
Discussion, it shall be filled with opinion of the Tax Auditor in
accordance with the SPHP.

Number (11) :

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 25 1.

Number (12) :
Number (13) :

Number (14) :

Number (15) :

Number (16) :

In terms of the Taxpayer attends the Audit Result Final


Discussion, it shall be filled with opinion of the Taxpayer in
the Final Discussion.
2.
In terms of the Taxpayer does not attend in the Audit Result
Final Discussion, it shall be filled with description regarding
the absence of the Taxpayer
Filled with sequence number.
Filled with corrected posts as listed in the Audit findings list of
which attached in the Audit Result Notification Letter.
Example:
The corrected item is the gross income item then it shall be filled
with Business Circulation.
Filled with correction amount as listed in the Audit findings lis,
which is attached in the SPHP.
Example:
Correction amount on the gross income item according to the Tax
Auditor in the Audit findings list is 400.000 then it shall be filled
with 400.000.
Filled with
1. In terms of the Taxpayer submits the written response on the
SPHP, it shall be filled with the amount which approved by the
Taxpayer as contained in the written response.
Example:
On the business circulation pos, which was corrected by the
Tax Auditor, the Taxpayer in the written response stating that
only he approves at the amount of 250.000 then it shall be be
filled with 250.000.
2. In terms of the Taxpayer does not submit a written response on
the APHP but attending Audit Result Final Discussion, it shall
be filled with the amount that is approved by the Taxpayer in
the final discussion.
Example:
The Taxpayer does not submit written response on the APHP
but attending in the Audit Result Final Discussion, and
certifying that of which is in the gross income item, which is
corrected by the Tax Auditor is only approved in the amount of
250.000 then it shall be filled with 250.000.
3. In terms of the Taxpayer does not submit the written response
on the SPHP and does not attend the Audit Result Final
Discussion, it shall be filled with the correction amount
according to the Audit findings list which attached in the
SPHP.
1.

In terms of the Taxpayer submit the written response and


attend in the Audit Result Final Discussion, or does not

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 26 submit a written response but attending the Audit Result


Final Discussion, it shall be filled with correction amount
according the Tax Auditor in accordance with the final
discussion result
Example:
After performing the final discussion with the Taxpayer, the
Tax Auditor concludes that the gross income correction
amount that is initially in the Audit Findings List is 400.000
becomes 350.000 then it shall be filled with 350.000.
2.
In terms of the Taxpayer submits the written response on the
SPHP but does not attend in the Audit Result Final
Discussion, it shall be filled with correction amount according
the Tax Auditor in accordance with the Audit Findings List by
attention to the Taxpayers written response.
Example:
The taxpayer submit a written response on the SPHP and
stating that on the business circulation correction at the
amount of 400.000 which was conveyed by the Tax Auditor,
the Taxpayer only approving in the amount of 250.000. Based
on the written response and by attention to the reason that is
conveyed by the Taxpayer, the Tax Auditor concludes that the
gross income of which is initially 400.000 becomes 375.000
then it shall be filled with 375.000.
3. In terms of the Taxpayer does not submit the written response on SPHP
and it does not attend Audit Result Final Discussion, it shall be filled
with the correction amount according to the Tax Auditor in accordance
with the Audit Findings List of which becames the SPHP attachment.
Number (17) :
1. In terms of the Taxpayer attends Audit Result Final Discussion,
it shall be filled with the value that approved by the Tax Auditor
in accordance with the Audit Result Final Discussion.
2. In terms of the Taxpayer submits a written response but it does
not attend in the Audit Result Final Discussion, it shall be filled
with the amount that approved by the Taxpayer as contained in
the written response.
3. In terms of the Taxpayer does not submit written response and
does not attend Audit Result Final Discussion, it shall be filled
with the correction amount according to the Tax Auditor in
accordance with the Audit Findings List as attached in SPHP.
Number (18) : Filled with location and date when the treatise of discussion is
made.
Number (19) : Filled with signature and name of the Taxpayer, Taxpayers
representative, or Taxpayers proxy.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 27 Number (20) :
Number (21) :
Number (22) :
Number (23) :
Number (24) :
Annotation*) :

Filled with position name of the head of Audit executor unit who
signs the treatise of discussion.
Filled with signature, name, NIP and position stamp of head of
Audit executor unit.
Filled with signature, name, and NIP of the Tax Auditor team
supervisor.
Filled with signature, name, and NIP of the Tax Auditor team
leader.
Filled with signature, name, and NIP of the Tax Auditor team
member.
Filled by crossing out the unnecessary.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 28 H.

REQUEST LETTER OF DISCUSSION WITH THE AUDIT QUALITY


ASSURANCE TEAM

.
(1)
Dear Sir/ Madam,
In connection with the Audit result final discussion with the Tax Auditor
team on the Audit Result Notification Letter number (2) date
.. (3), I, hereby:
Name
: . (4)
Occupation/Position : . (5)
Address
: . (6)
In this case acted as:
Taxpayer
Representative
Proxy
of the Taxpayer:
Name
: ...
TIN
Address

:
: ...

(7)
(8)
(9)
(10)

request for discussion with the Audit Quality Assurance Team over the
disagreements that still occuring with the Tax Auditor team in the Audit result final
discussion process as contained in the Treatise of Discussion.
As for the correction items of which are required to discuss with the Audit
Quality Assurance Team as follows:
Number

Corrected items
of which
requested to be
discussed.

Correction
conform with
SPHP

(11)

(12)

(13)

Correction Conform with Audit Result


Conform with
Conform with
Tax Auditor
Taxpayer
(14)

(15)

In order to discuss such differences, hereby I inform you the contact numbers of
which could be called by the Audit Quality Assurance Team as follow:
Phone Number
: (16)
Mobile
: (17)
Fax
: (18)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 29 -

In witness whereof, this request letter is made, thank you for your kind attention.
.,
(19)

.
(20)
Copy to:
. (21)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 30 FILLING INSTRUCTION OF REQUEST LETTER OF DISCUSSION WITH THE AUDIT


QUALITY ASSURANCE TEAM
Number (1)

Number (2)
Number (3)
Number (4)

:
:
:

Number (5)

Number (6)

Number
Number
Number
Number
Number
Number

:
:
:
:
:
:

(7)
(8)
(9)
(10)
(11)
(12)

Number (13) :
Number (14) :
Number (15) :
Number
Number
Number
Number

(16)
(17)
(18)
(19)

:
:
:
:

Number (20) :
Number (21) :

Filled with Director of Audit and Collection in terms of the Audit


performed by the Directorate of Audit and Collection or the head of
Regional Office of the Directorate General of Taxation who oversees
the Audit executor unit in terms of the Audit is performed by the
Tax Service Office.
Filled with number of the SPHP.
Filled with date of the SPHP.
Filled with name of the Taxpayer, Taxpayers representative, or
Taxpayers proxy who applies for request.
Filled with occupation/position of the Taxpayer, Taxpayers
representative, or the Taxpayers proxy who applies for the
request.
Filled with the address of the Taxpayer, Taxpayers representative,
or the Taxpayers proxy who applies for the request.
Filled by marking [ ] in the appropriate box.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with sequence number.
Filled with posts which are requested by the Taxpayer to be
performed the discussion with the Audit Quality Assurance Team.
Filled with correction value in accordance with the Audit findings
list that becomes the Audit Result Notification Letter attachment.
Filled with correction value according to the Tax Auditor in
accordance with the Audit Result Final Discussion result, which
contained in the treatise of discussion.
Filled with correction value which was approved according to the
Taxpayer in accordance with the Audit Result Final Discussion
result, which contained in the treatise of discussion.
Filled with phone number of the Taxpayers party.
Filled with mobile phone number of the Taxpayers party.
Filled with fax number of the Taxpayers party that can be used.
Filled with location and date when the request letter was made.
Filled with name and signature of the Taxpayer, Taxpayers
Representative, or Taxpayers proxy.
Filled with head of Audit executor unit.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 31 I.

INVITATION TO ATTEND THE DISCUSSION WITH THE AUDIT QUALITY


ASSURANCE TEAM:
Ministry
of finance
logo

Number
(3)
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)
: (2)

., .

: Immediately
: (4)
: Invitation to Attend the Discussion with the Audit Quality Assurance
Team

...
. (5)
Dear Sir/ Madam,
In connection with the Request Letter of Audit Result Final Discussion
with the Audit Quality Assurance Team that you has been submitted on the date of
.. (6), we hereby invite you on:
Day/date
: (7)
Time
: (8)
Venue
: (9)
to held discussion for the difference of opinion between you and the Tax Auditor
team as contained in your request letter.
Should you does not attend the discussion in accordance with the day
and date mentioned above, the discussion with the Audit Quality Assurance Team
shall be deemed have been performed.
In witness whereof this invitation is made and thank you for your
cooperation.
Faithfully Yours,
..
(
10)

..
NIP ..
11)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 32 Copy to:
(12)
Received by
Position
Date
Signature/ stamp

: ..
: .
: .
: .

(13)
(14)
(15)
(16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 33 FILLING INSTRUCTION OF INVITATION TO ATTEND THE DISCUSSION WITH THE


AUDIT QUALITY ASSURANCE TEAM
Number (1) : Filled with letterhead.
Number (2) : Filled with number of the Invitation to Attend the Discussion with the
Audit Quality Assurance Team.
Number (3) : Filled with date of the Invitation to Attend the Discussion with the
Audit Quality Assurance Team.
Number (4) : Filled with number of attachment.
Number (5) : Filled with name and address of the invited Taxpayer.
Number (6) : Filled with date when the Taxpayers request letter is received.
Number (7) : Filled with day and date when the discussion is held.
Number (8) : Filled with time of the discussion implementation.
Number (9) : Filled with location of the discussion implementation.
Number (10) : Filled with position name of the head of Audit executor unit.
Number (11) : Filled with signature, name, NIP, and position stamp of the official
who signs the invitation.
Number (12) : Filled with vertical unit who oversees the Audit executor unit.
Number (13) : Filled with name of a person who receives the Invitation to Attend the
Discussion by the Audit Quality Assurance Team.
Number (14) : Filled with position of a person who receives the Invitation to Attend
the Discussion by the Audit Quality Assurance Team.
Number (15) : Filled with the receiving date of the Invitation to Attend the
Discussion by the Audit Quality Assurance Team.
Number (16) : Filled with signature of a person and company stamp who receives
the Invitation to Attend the Discussion by the Audit Quality
Assurance Team.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 34 J. FORMAT OF THE TREATISE OF AUDIT QUALITY ASSURANCE TEAM:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)

THE TREATISE OF AUDIT QUALITY ASSURANCE TEAM


SP2 Number
: date .. (2)
Name of Taxpayer
: . (3)
TIN
Address

:
(4)
: . (5)

Tax Period and Fiscal year :

(6)

1. Subject Matter that Has Not Been Agreed


.
.
(7)
a. Taxpayers opinion during the discussion with the Audit Quality
Assurance Team.
..
..
(8)
b. Tax Auditors opinion during the discussion with the Audit Quality
Assurance Team.
..
..
(9)
c. Conclusion and decision of the Audit Quality Assurance Team
.
.
(10)
d. Taxpayers response on the Conclusion and decision of the Audit
Quality Assurance Team
.
.
(11)
e. Tax Auditor response on the Conclusion and decision of the Audit
Quality Assurance Team
.
.
(12)
2. Subject Matter Which Has Not Been Agreed
.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 35 .
(7)
a. Taxpayers opinion during the discussion with the Audit Quality
Assurance Team.
..
..
(8)
b. Tax Auditors opinion during the discussion with the Audit Quality
Assurance Team.
..
..
(9)
c. Conclusion and decision of the Audit Quality Assurance Team
.
.
(10)
d. Taxpayers response on the Conclusion and decision of the Audit
Quality Assurance Team
.
.
(11)
e. Tax Auditor response on the Conclusion and decision of the Audit
Quality Assurance Team
.
.
(12)
3. And so on.
4. Audit Result Conclusion:
Number Items that are Correction Conform
Correction Conform with Audit
Requested to
with Audit Result
Quality Assurance Team
be Discussed.
Decision
Conform Conform
Conform
Conform with
with Tax
with
with Audit
Taxpayer
Auditor
Taxpayer
Quality
Assurance
Team
(13)

(14)

(15)

Taxpayer/Representative/Proxy*)

(16)

(17)
(18)
.,
Tax Auditor Team

(19)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 36 . (20)
...
NIP

(21)

Audit Quality Assurance Team


Leader

Member

NIP . (22)
Secretary

NIP

.
NIP . (23)

(24)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 37 FILLING INSTRUCTION OF THE TREATISE OF AUDIT QUALITY ASSURANCE TEAM


Number
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)
(7)

:
:
:
:
:
:
:

Filled with letterhead,


Filled with number and date of Tax Audit Order Letter.
Filled with name of the audited Taxpayer.
Filled with Tax Identification of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with the audited Tax Period and Fiscal Year.
Filled with corrected post and correction value according to the Tax
Auditor and Taxpayers response in accordance with the Audit
Result Final Discussion as contained in the Treatise of Discussion.
Number (8) : Filled with description or explanation that was presented by the
Taxpayer in the discussion with the Audit Quality Assurance Team.
Number (9) : Filled with description or explanation that is presented by the Tax
Auditor in the discussion with the Audit Quality Assurance Team.
Number (10) : Filled with conclusion and decision of the Audit Quality Assurance
Team on the differences of opinion between the Tax Auditor with the
Taxpayer.
Number (11) : Filled with Taxpayers response on the conclusion and decision of
the Audit Quality Assurance Team.
Number (12) : Filled with Tax Auditors response on the conclusion and decision of
the Audit Quality Assurance Team.
Number (13) : Filled with sequence number.
Number (14) : Filled with corrected posts that is requested by the Taxpayer to
discuss with the Audit Quality Assurance Team.
Number (15) : Filled with correction amount according to the Tax Auditor in
accordance with the Audit Result Final Discussion as contained in
the treatise of discussion.
Number (16) : Filled with correction amount which was approved by the Taxpayer
in accordance with the Audit Result Final Discussion as contained
in the treatise of discussion.
Number (17) :
Filled with correction amount that is decided by the Audit
Quality Assurance Team in the discussion.
Number (18) :
1. In terms of the Taxpayer attends in the discussion with the Audit
Quality Assurance Team, filled with the correction amount which is
approved by the Taxpayer in the discussion.
2. In terms of the Taxpayer does not attend discussion with the Audit
Quality Assurance Team, filled with the correction amount that is
approved by the Taxpayer in the Audit Result Final Discussion with
the Tax Auditor as contained in the treatise of discussion
Number (19) : Filled with location and date when the treatise of discussion is
made.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 38 Number (20) : Filled with signature and name of the Taxpayer, Taxpayers
representative, or Taxpayers proxy.
Number (21) : Filled with position, signature, name and NIP of the Tax Auditor
(adjusted with the number of Tax Auditor team attend).
Number (22) : Filled with signature, name and NIP of the Audit Quality Assurance
Team leader.
Number (23) : Filled with signature, name and NIP of the Audit Quality Assurance
team secretary.
Number (24) : Filled with signature, name and NIP of the Audit Quality Assurance
team member (adjusted with the number of team member attend).

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 39 K.

FORMAT OF THE MINUTE OF AUDIT RESULT FINAL DISCUSSION THAT IS


ATTACHED WITH THE TREATISE OF FINAL DISCUSSION RESULT AND THE
TREATISE OF FINAL DISCUSSION RESULT.

K1.

FORMAT OF THE MINUTE OF THE AUDIT RESULT FINAL DISCUSSION


THAT IS ATTACHED WITH THE TREATISE OF FINAL DISCUSSION RESULT
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)
THE MINUTE OF THE AUDIT RESULT FINAL DISCUSSION

On this day . (2) date (3) month .. (4) year


.. (5), located in .. (6), we:
Number.
Name /NIP
Rank / Class
Position
(7)
(8)
(9)
(10)
pursuant to the Tax Audit Order Letter number: . (11) date (12),
has performed Audit in the field of taxation to the Taxpayer:
Name :
..
(13)
TIN

:
(14)

and hereby inform as well as perform the Audit result final discussion with:
Taxpayer
(15)

Taxpayers Representative

Proxy

of

Taxpayer

Name
: . (16)
Position/Occupation
: . (17)
Address
: . (18)
In the form of items as mentioned in the attachment.
In witness whereof this minute is made truthfully and signed by:
Taxpayer/Representative/Proxy

.. (19)

Tax Auditor Team:


Supervisor,
..
NIP ..
(20)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 40 Acknowledged by:
(21)

Team Leader,

.
NIP
.

(23)
NIP (22)

Team member,

NIP . (24)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 41 FILLING INSTRUCTION OF THE MINUTE OF


AUDIT RESULT FINAL DISCUSSION
Number (1)
Number (2)
Number (3)
Number (4)
Number (5)
Number (6)
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number

(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)

Number (17)
Number (18)
Number (19)
Number (20)
Number (21)
Number (22)
Number (23)
Number (24)
Annotation*)

: Filled with letterhead.


: Filled with day when the minute of Audit Result Final Discussion is
signed.
: Filled with date when the minute of Audit Result Final Discussion is
signed.
: Filled with month when the minute of Audit Result Final Discussion
is signed.
: Filled with year when the minute of Audit Result Final Discussion is
signed.
: Filled with location in which the minute of Audit Result Final
Discussion is signed.
: Filled with sequence number.
: Filled with name and NIP of the Tax Auditor.
: Filled with rank/class of the Tax Auditor.
: Filled with position of the Tax Auditor.
: Filled with number of the SP2.
: Filled with date of the SP2.
: Filled with name of the audited Taxpayer.
: Filled with Tax Identification Number of the audited Taxpayer.
: Filled by mark [ ] on required box.
: Filled with name of the Taxpayer, Taxpayers representative, or
Taxpayers proxy.
: Filled with position/occupation of the Taxpayer, Taxpayers
representative, or Taxpayers proxy.
: Filled with address of the Taxpayer, Taxpayers representative, or
Taxpayers proxy.
: Filled with signature and name of the Taxpayer, Taxpayers
representative, or Taxpayers proxy.
: Filled with position name of the head of Audit executor unit who
signs the minute.
: Filled with signature, name, NIP, and position stamp of the official
who signs the letter.
: Filled with signature, name, and NIP of the Tax Auditor team
supervisor.
: Filled with signature, name, and NIP of the Tax Auditor team leader.
: Filled with signature, name, and NIP of the Tax Auditor team
member (adjusted with the number of Tax Auditor team member
attend).
: Filled by crossing out unnecessary.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 42 K2.

FORMAT OF TREATISE OF FINAL DISCUSSION RESULT:


Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)

Name of Taxpayer

TREATISE OF FINAL DISCUSSION RESULT:


: . (2)

TIN
:
(3)
Tax Period and Fiscal Year : . (4)
Description

(5)
I. Tax Object/
corporate
Taxpayers
Income Tax
II. Income
Tax Article 21
III. Income
Tax Article
22.
IV. Income
Tax Article 23
V. And so on.
VI. Other
Administrativ
e Sanctions.

Confor
m with
SPT

(6)

Correctio
n conform
with
SPHP

(7)

(13)
Taxpayer/Representative/Proxy*)
.. (14)
(17)
Acknowledged by:
.. (15)

Correction
Conform with
Discussion
Confor
Conform
m with
with
Audit
Taxpaye
r
(8)

(9)

Final Discussion
Result
Confor
m with
Audit
(10)

Which
approve
d by
Taxpaye
r
(11)

Cancelle
d/
added
findings

(12)

..
Tax Auditor Team:
Supervisor,
..
NIP ..
Team Leader,
..

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 43 ..

NIP ..

(18)
NIP .. (16)

Team member,

..
(19)

NIP ..

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 44 FILLING INSTRUCTION OF THE TREATISE OF FINAL DISCUSSION RESULT


Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)

Number (6)
Number (7)
Number (8)

:
:
:
:
:

Filled with letterhead.


Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the audited Tax Period and Fiscal Year.
Filled with corrected items of the Tax return for each type of Tax,
including payable tax post, tax credit, and underpayment tax and
administrative sanction.
: Filled with numbers in accordance with the Taxpayers Tax return.
: Filled with Auditor correction in accordance with Tax Audit findings
list that become an attachment of SPHP.
: Filled with
1. In terms of not performing a discussion with the Audit Quality
Assurance Team, filled with correction amount according the
Auditor in accordance with Number 16 of the treatise of
discussion.
2. In terms of performing a discussion with the Audit Quality
Assurance Team, filled with correction amount which was
decided by the Audit Quality Assurance Team in accordance
with Number 17 of the treatise of Audit Quality Assurance
Team Discussion.

Number (9)

:
1. In terms of not performing a discussion with the Audit Quality
Assurance Team, filled with correction amount that is approved
by the Taxpayer in accordance with Number 17 of the Treatise
of Discussion.
2. In terms of performing a discussion with the Audit Quality
Assurance Team, filled with correction amount which was
approved by the Taxpayer in accordance with Number 18 of
the treatise of Audit Quality Assurance Team Discussion.

Number (10) : Filled with calculation result of Number 6 added with Number 8.
Number (11) : Filled with calculation result of Number 6 added with Number 9.
Number (12) : Filled with calculation result of Number 6 added with Number 7
minus Number 10.
Number (13) : Filled with location and date when the treatise of final discussion
result is made.
Number (14) : Filled with signature and name of the Taxpayer, Taxpayers
representative, or the Taxpayers proxy.
Number (15) : Filled with position name of the head of Audit executor unit who
signs the letter.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 45 Number (16) : Filled with signature, name, NIP, and position stamp of the official
who signs the letter.
Number (17) : Filled with signature, name, and NIP of the Tax Auditor team
supervisor.
Number (18) : Filled with signature, name, and NIP of the Tax Auditor team
leader.
Number (19) : Filled with signature, name, and NIP of the Tax Auditor team
member.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 46 L.

FORMAT OF SUMMON TO SIGN THE MINUTE OF AUDIT RESULT FINAL


DISCUSSION:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)

Number
: .. (2)
..,
(3)
Nature
: Immediately
Attachment : .. (4)
Subject
: summon to sign the minute of Audit Result Final Discussion
. ..
.
.. (5)
Dear Sir/ Madam,
As the implementation of the Regulation of Minister of Finance Number
/PMK.03/
concerning Audit procedures and Treatise of Discussion has been
made and the Treatise of Audit Quality Assurance Team Discussion*) has been
received pursuant to the Tax Audit Warrant Number: ... (6) date .. (7), we
hereby require your presence on:
Day/Date : (8)
Time
: (9)
Venue
:
(10)
to sign the minute of the Audit Result Final Discussion.
In witness whereof this summon is made and thank you for your
cooperation.
Yours Faithfully,
.. (11)

..
NIP (12)
Received by
Position
Date
Signature/ stamp

: .
: .
: .
: .

(13)
(14)
(15)
(16)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 47 FILLING INSTRUCTION OF SUMMONS TO SIGN THE MINUTE OF AUDIT RESULT


FINAL DISCUSSION
Number (1)
Number (2)
Number (3)
Number
Number
Number
Number
Number
Number
Number
Number
Number

(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)

Number
Number
Number
Number

(13)
(14)
(15)
(16)

Annotation*)

: Filled with letterhead.


: Filled with number of the summon to sign the minute of the Audit
Result Final Discussion.
: Filled with location, and date of the summon to sign the minute of
the Audit Result Final Discussion.
: Filled with number of document attached.
: Filled with name and address of the Taxpayer.
: Filled with number of the SP2.
: Filled with date of the SP2.
: Filled with day and date when the Taxpayer requested to attend.
: Filled with time/hour when the Taxpayer requested to attend.
: Filled with address where the Taxpayer requested to attend.
: Filled with position name of the official who was signed the letter.
: Filled with signature, name, NIP, and position stamp official signs
the letter.
: Filled with name of a person who receives the summons.
: Filled with position of a person who receives the summons.
: Filled with date when the summon is received.
: Filled with signature and stamp of a company that receives the
summons.
: Written if there is a treatise of Audit Quality Assurance Team
Discussion.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 48 M.

FORMAT OF THE MINUTE OF TAXPAYER'S ABSENCE FOR AUDIT RESULT


FINAL DISCUSSION
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)

THE MINUTE OF THE TAXPAYER'S ABSENCE IN ORDER OF AUDIT RESULT


FINAL DISCUSSION
On this day . (2) date (3) month .. (4) year
.. (5), located in .. (6), based on the Tax Audit Order Letter number
. (7) date (8), we:
Number
Name /NIP
Rank / Class
Position
(9)
(10)
(11)
(12)
who assigns to perform an Audit on the Taxpayer:
Name

: .

(13)

TIN
Address

:
: ....

(14)
(15)

Period and Fiscal Year :


(16)
has provided an opportunity to the Taxpayer to submit written response and
present in order of Audit result final discussion in accordance with the Audit
Result Tax return number .. (17) date (18), but the Taxpayer
does not present within predetermined time.
In witness whereof this minute is made truthfully upon power of the oath of
office, then it is closed and signed by the Tax Auditor team.
Tax Auditor Team:
Acknowledged by:
Supervisor,
(19)

NIP (20)

(21)
NIP
Team Leader,

NIP (22)
Team member,

NIP (23)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 49 FILLING INSTRUCTION OF THE MINUTE OF THE TAXPAYER'S ABSENCE


Number (1)
Number (2)
Number (3)
Number (4)
Number (5)
Number (6)
Number
Number
Number
Number
Number
Number

(7)
(8)
(9)
(10)
(11)
(12)

Number
Number
Number
Number

(13)
(14)
(15)
(16)

Number
Number
Number
Number

(17)
(18)
(19)
(20)

Number (21)
Number (22)
Number (23)

: Filled with letterhead.


: Filled with the day when the minute of the Taxpayers absence is
signed.
: Filled with the date when the minute of the Taxpayers absence is
signed.
: Filled with the month when the minute of the Taxpayers absence is
signed.
: Filled with the year when the minute of the Taxpayers absence is
signed.
: Filled with the location where the minute of the Taxpayers absence
is signed.
: Filled with number of SP2.
: Filled with date of SP2.
: Filled with sequence number.
: Filled with name and NIP of the Tax Auditor Team.
: Filled with rank and class of the Tax Auditor Team.
: Filled with position of the Tax Auditor Team. which is supervisor,
team leader, or team member
: Filled with name of the audited Taxpayer.
: Filled with Tax Identification Number of the audited Taxpayer.
: Filled with the address of the audited Taxpayer.
: Filled with Filled with Tax Period and Fiscal Year which will be
audited
: Filled with number of The SPHP.
: Filled with the date of The SPHP.
: Filled with position name of the head of Audit Executor Unit.
: Filled with signature, name, NIP, and position stamp of the head of
Audit Executor Unit.
: Filled with signature, name and NIP of the Tax Auditor team
supervisor.
: Filled with signature, name and NIP of the Tax Auditor team leader.
: Filled with signature, name and NIP of the Tax Auditor team
member.

Copy as
original version
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION
OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
MARTOWARDOJO

MINISTER OF FINANCE OF THE


REPUBLIC OF INDONESIA
Signed

AGUS D.W.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 50 -

APPENDIX VIII
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

FORMAT REPORT FOR


THE DISCLOSURE
OF UNTRUTH FILLING OF TAX RETURN
. .
(1)
Dear Sir/ Madam,
I, Hereby:
Name
Occupation/Position
Address
In this case acted as:
Taxpayer
of the Taxpayer:
Name
TIN
Address

: (2)
: (3)
: (4)
Representative

Proxy

(5)

: (6)
:
(7)
: (8)

with my own consciousness reveals the untruth filling of the Tax return of
(9) Tax Period/Fiscal Year (10), which has been
reported with the Receipt of acceptance number . (11) date ..
(12).
In accordance with the provisions of Article 8 clause (4) of Law Number 6
Year 1983 concerning General Provisions and Tax Procedures as it has been several
times amended lastly with Law Number 16 Year 2009, we delivered this report of
the disclosure of untruth filling of Tax return ,which results:
Tax payable become bigger
(13)
Tax payable become smaller
(14)
Loss based on tax provision become smaller
(15)
Loss based on tax provision become bigger
(16)
Amount of asset become bigger
(17)
Amount of asset become smaller
(18)
Amount of capital become bigger
(19)
Amount of capital become smaller
(20)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2As for the Tax Return element whose the filling is not in accordance with the
actual condition is as follows:
1. Form/Attachment (21)
a. Untruth disclosures on ...(22)
Tax Return
IDR .. (23)
Actual Condition
IDR ............ (24)
Difference
IDR (25)
b. Description regarding the untruth filling of Tax return

.
(26)
2. Form/Attachment ... (21)
c. Untruth disclosures on ...(22)
Tax Return
IDR (23)
Actual Condition
IDR ............. (24)
Difference
IDR (25)
d. Description regarding the untruth filling of Tax return

..

..
(26)
3. And so on.
Disclosure of untruth in the filling of Tax Return as listed above results tax
underpayment in the amount of: IDR (27) says () (28)
Herewith, we attached:
1. Tax underpayment calculation in accordance with the actual condition in the
format of Tax return. (29)
2. Tax Payment Slip as a proof of payment of tax underpayment in the amount of
IDR (30), which has been paid on the date of
(31) through (32)
3. Tax Payment Slip as a proof of payment of administrative sanction in the form
of an increase of 50% amounting to IDR (33), which has
been paid on the date of (34) through (35)
4. Documents, which become the basis of the tax return untruth filling
disclosure.
With full awareness of all legal consequences arise, we certify that:

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-31.

Have revealed all of untruth in connection with the Tax return as mentioned
above.
2. Will perform rectification of the Annual/Periodic Tax return on other tax
periods/fiscal year if there was a connection with the Tax return that we
reveals the untruth filling.
3. Willing to give information, documents, and/or proof which related to the Tax
return untruth filling disclosure.
4. Will not repeating the same actions for the future.
In witness whereof this disclosure of untruth in filling of the Tax return is
revealed to be followed up in accordance with the provisions of the applicable
legislation.
Yours Faithfully,
,
(36)
..

(37)

..
(38)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4FILLING INSTRUCTION OF THE DISCLOSURE REPORT OF UNTRUTH FILLING OF


TAX RETURN
Number (1)
Number (2)
Number (3)
Number (4)
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number

(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)
(21)

: Filled with name and address of the Tax Service Office in which the
Taxpayer registered.
: Filled with name of the Taxpayer, Taxpayers representative, or of
Taxpayers proxy who signs the disclosure report.
: Filled with occupation/position of the Taxpayer, Taxpayers
representative, or of Taxpayers proxy who signs the disclosure
report
: Filled with the address of the Taxpayer, Taxpayers representative,
or of Taxpayers proxy who signs the disclosure report.
: Filled with [ ] sign in appropriate box.
: Filled with name of the audited Taxpayer.
: Filled with Tax Identification Number of the audited Taxpayer.
: Filled with the address of the audited Taxpayer.
: Filled with type of Tax Return
: Filled with Tax Period/Fiscal Year of the Tax Return
: Filled with proof of mailing number (BPS).
: Filled with proof of mailing date (BPS).
: Filled with [ ] sign if Accrued Tax become bigger
: Filled with [ ] sign if Accrued Tax become smaller.
: Filled with [ ] sign if Loss based on tax provision become smaller.
: Filled with [ ] sign if Loss based on tax provision become bigger.
: Filled with [ ] sign if Amount of asset become bigger.
: Filled with [ ] sign if Amount of asset become smaller.
: Filled with [ ] sign if Amount of capital become bigger.
: Filled with [ ] sign if Amount of capital become smaller.
: Filled with Form code or Tax Return Attachment that contained the
untruth filling.
Example :
a.
b.

In the case of Domestic Input VAT crediting not in accordance


with the actual transaction, filled with: Form 1107-B
In the case of under reported business circulation, filled with:
Form 1771 Attachment I.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5Number (22) : Filled with post or part of Tax Return Form or Attachment, which
contains untruth filling.
Example:
a. In the case of Domestic Input VAT crediting not in accordance
with the actual transaction, it shall be filled with: BKP/JKP
Purchasing from Domestic.
b. In the case of under reported business circulation, it shall be
filled with: Business Circulation.
Number (23) : Filled with reported amount in the Tax Return.
Number (24) : Filled with the amount that should be reported in accordance with
the actual condition.
Number (25) : Filled with the differences between amount that should be reported
with the reported amount in the Tax Return.
Number (26) : Filled with description and explanation regarding the revealed
amount of Tax Return untruth filling.
Example:
In the case of Domestic Input VAT crediting not in accordance with
the actual transaction, it shall be filled with: there are VAT
crediting on goods purchase from PT. X in the amount of 20 sheets
of tax invoices with the Tax Basis value of IDR 3.500.000,00 and
VAT of IDR 350.000,00 that should not be counted against the
Output Vat, because the tax invoices is not in accordance with the
actual transaction.
Number (27) : Filled with tax underpayment principal amount if the Tax Return
untruth filling disclosure causes the tax become underpayment.
Example: IDR 350.000.000,00.
Number (28) : Filled with tax underpayment principal amount due to the Tax
Return untruth filling disclosure in letter, example: Three hundred
and fifty million rupiahs.
Number (29) : Made using Tax Return Form that is in accordance with information
providing In Order of Tax Return Untruth Filling Disclosure in
accordance with Article 8 clause (4) of the Law of KUP at top of the
first page of related form and signed by the Taxpayer.
Number (30) : Filled with Tax Payment Slip nominal amount on tax underpayment
principal.
Number (31) : Filled with date of tax underpayment principal deposits.
Number (32) : Filled with location of tax underpayment principal deposits.
Number (33) : Filled with Tax Payment Slip nominal amount on administrative
sanction in the form of an increase of 50%.
Number (34) : Filled with date of deposits of administrative sanction in the form of
an increase of 50%
Number (35) : Filled with location of deposits of administrative sanction in the
form of an increase of 50%.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6Number (36) : Filled with location and date when the Tax Return untruth filling
disclosure report is made.
Number (37) : Filled with name of the Taxpayer, Taxpayers Representative, or
Power of the Taxpayer who signed the Tax Return untruth filling
disclosure report.
Number (38) : Filled with occupation/position of the Taxpayer, Taxpayers
representatives, or the Taxpayers proxy who signs the Tax Return
untruth filling disclosure report.
Copy as its
MINISTER OF FINANCE OF THE
original version
REPUBLIC OF INDONESIA
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION
Signed
OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
AGUS D.W.
MARTOWARDOJO

APPENDIX IX
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

A. FORMAT OF NOTIFICATION OF EXAMINATION PERIOD EXTENSION:

Ministry
of finance
logo

Number
(3)
Nature
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
.. (1)
: . (2)

., ..

: Immediately
: Examination Period Extension Notification

.. .
... (4)
Dear Sir/ Madam,
In connection with the Audit implementation in the field of taxation on your
company/occupation here below:
Name
: .. (5)
TIN
Address

:
(6)
: .. (7)

Tax Period and Fiscal Year :


(8)
Audit Purposes
: To Examine The Fulfillment Compliance of Tax
Obligations.
Pursuant to the Tax Audit Warrant number . (9) date
.. (10) we hereby inform you that the Audit examination period, is
extended for (11) month(s) with the reason of (12).
In witness whereof, thank you for taking this into consideration
Yours Faithfully,.

(13)

NIP.

Copy to:
(15)
Received by
Position
Date
Signature/ stamp

:
:
:
:

(16)
(17)
(18)
(19)

14)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-2FILLING INSTRUCTION OF NOTIFICATION LETTER OF


EXAMINATION PERIOD EXTENSION
Number
Number
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)

:
:
:
:
:
:
:
:

Filled with
Filled with
Filled with
Filled with
Filled with
Filled with
Filled with
Filled with
Example:

letterhead.
letter number.
letter date.
name and address of the audited Taxpayer.
name of the audited Taxpayer.
Tax Identification Number of the audited Taxpayer.
the address of the audited Taxpayer.
Tax Period and Fiscal Year to be audited.

1. The Audit was performed for Tax Period of January to May of


2001, then it shall be filled with:
0 1 1 1
0 5 1 1
2. The Audit was performed for Fiscal Year of 2011 and the
accounting year is the same with calendar year, then it shall be
filled with:
0 1 1 1
1 2 1 1
3. The Audit was performed for Fiscal Year of 2011, but the
accounting year commencing from April 1, 2011 until March 31,
2012, then it shall be filled with:
0 4 1 1
0 3 1 2
Number
Number
Number
Number
Number
Number

(9)
(10)
(11)
(12)
(13)
(14)

:
:
:
:
:
:

Filled with SP2 number.


Filled with SP2 date.
Filled with extension period.
Filled with the reason of examination period extension.
Filled with position name of the head of Audit executor unit.
Filled with signature, name, NIP and position stamp of the head of
Audit executor unit.
Number (15) : Filled with:
1.

Director of Audit and Collection in terms of the Audit


instruction/approval was issued by the Director General of
Taxation or the Director of Audit and Collection; or
2. Head of Director General of Taxation Regional Office in terms of
the Audit instruction/approval/assignment was issued by the
Head of Director General of Taxation Regional Office.
Number (16) : Filled with name of a person who receives the notification letter of
examination period extension.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3Number (17) : Filled with position of a person who receives the notification letter of
examination period extension.
Number (18) : Filled with date when the notification letter of examination period
extension is received.
Number (19) : Filled with signature and company stamp who receives the
notification letter of examination period extension.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4B.

FORMAT OF NOTIFICATION OF AUDIT SUSPENSION THAT IS ENHANCED TO


THE PRELIMINARY EVIDENCE AUDIT:
Ministry
of finance
logo

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
. (1)

Number
Nature
Attachment
Subject

:
:
:
:

. (2)
, (3)
Immediately
Notification of Audit Suspension that
is Enhanced To the Initial Evidence
Audit
. ..
.
. (4)
Dear Sir/ Madam,
In connection with the Audit in the field of taxation that we performed on
your company/occupation here below:
Name
: .. (5)
TIN
:
(6)
Address
: .. (7)
Tax Period and Fiscal Year:
(8)
pursuant to the Tax Audit Warrant number . (9) date
(10), hereby we inform that the Audit shall be suspended due to
the audit is enhanced to Preliminary Evidence Audit.
In witness whereof this notification is made and thank you for taking this youre
your consideration.
Yours Faithfully,
..
(11)
..
..

(12)
Copy to:
(13)
Received by
Position
Date
Signature/ stamp

:
:
:
:

(14)
(15)
(16)
(17)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-5FILLING INSTRUCTION OF NOTIFICATION OF AUDIT SUSPENSION THAT IS


ENHANCED TO THE PRELIMINARY EVIDENCE AUDIT
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)

Number (13)

:
:
:
:
:
:
:
:
:
:
:
:

Filled with letterhead.


Filled with letter number.
Filled with date of the letter.
Filled with name and address of the Taxpayer.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with the audited Tax Period and Fiscal Year.
Filled with SP2 number.
Filled with date of the SP2.
Filled with position name of the head of Audit executor unit.
Filled with signature, name, NIP and position stamp of the head
of Audit executor unit.
: Filled with:
1. Director of Intelligence and Investigation in terms of the
Preliminary Evidence Audit is performed by the Directorate of
Intelligence and Investigation; or
2. Head of Director General of Taxation Regional Office in terms of
the Preliminary Evidence Audit is performed by the Head of the
Regional Office of Director General of Tax.

Number (14)
Number (15)
Number (16)
Number (17)

: Filled with name of a person who receives the notification of Audit


suspension that is enhanced to the Preliminary Evidence Audit.
: Filled with position of a person who receives the notification of
Audit suspension that is enhanced to the Preliminary Evidence
Audit.
: Filled with date when the notification of Audit suspension that is
enhanced to the Preliminary Evidence Audit is received.
: Filled with company stamp and signature of a person who
received the notification of Audit suspension that is enhanced to
the Preliminary Evidence Audit.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-6C.

FORMAT OF NOTIFICATION OF AUDIT TERMINATION:


Ministry
of finance
logo

Number
(3)
Nature
Attachment
Subject

MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA


DIRECTORATE GENERAL OF TAX
(1)
: . (2)

, ..

: Immediately
:: Notification of Audit Termination

.
. (4)
Dear Sir/ Madam,
In connection with the notification of Audit suspension that is enhanced to
the Preliminary Evidence Audit number . (5) date
.. (6), we hereby inform that the Audit that is performed on your
company/occupation:
Name
: .. (7)
TIN
Address

:
: ..

(8)
(9)

Tax Period and Fiscal Year :


(10)
pursuant to the Tax Audit Warrant number (11) date (12),
is terminated because ... (13).
In witness whereof this notification is made and thank you for taking this
into your concern
Yours Faithfully.

(14)
.
NIP..
(15)
Copy to:
(16)
Received by
Position
Date
Signature/ stamp

: ..
: ..
: ..
: ..

(17)
(18)
(19)
(20)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-7FILLING INSTRUCTION OF NOTIFICATION OF AUDIT TERMINATION


Number
Number
Number
Number
Number

(1)
(2)
(3)
(4)
(5)

:
:
:
:
:

Number (6)

Number
Number
Number
Number
Number
Number
Number

:
:
:
:
:
:
:

(7)
(8)
(9)
(10)
(11)
(12)
(13)

Number (14) :
Number (15) :
Number (16) :

Filled with letterhead.


Filled with letter number.
Filled with date of the letter.
Filled with name and address of the Taxpayer.
Filled with number of the notification of Audit suspension that is
enhanced to the Preliminary Evidence Audit.
Filled with date of the notification of Audit suspension that is
enhanced to the Preliminary Evidence Audit.
Filled with name of the audited Taxpayer.
Filled with Tax Identification Number of the audited Taxpayer.
Filled with the address of the audited Taxpayer.
Filled with the audited Tax Period and Fiscal Year.
Filled with SP2 number.
Filled with date of the SP2.
Filled with the reason of Audit termination as set forth in Article 12
clause (4) of the Governmental Regulation Number 74 Year 2011.
Filled with position name of the head of Audit executor unit.
Filled with signature, name, NIP and position stamp of the head of
Audit executor unit.
Filled with:
1.
2.

Director of Intelligence and Investigation in terms of the Initial


Evidence Audit/Investigation performed by the Directorate of
Intelligence and Investigation; or
Head of Director General of Taxation Regional Office in terms of
the Initial Evidence Audit/Investigation performed by the Head
of Regional Office the Director General of Tax.

Number (17) : Filled with name of a person who receives the notification of Audit
termination.
Number (18) : Filled with position of a person who receives the notification of Audit
termination.
Number (19) : Filled with date when the notification of Audit termination is
received.
Number (17) : Filled with company stamp and signature of a person who receives
the notification of Audit termination.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-8D. QUESTIONNAIRE OF FIELD AUDIT IMPLEMENTATION TO EXAMINE THE


FULFILLMENT COMPLIANCE OF TAX OBLIGATIONS.
For improving the Audit quality and accountability, feedback in the form of
questioner answer is necessary, we expect you could cooperate in the form of your
willingness to answer the following List of Questionnaire. Considering your answer
is essential for the Audit policy improvement in the future, it is expected that you
could give the answers in accordance with the actual situation. Accordingly, thank
you for your cooperation.
NUMBER
QUESTION
1
During the Audit, does the Tax Auditor show Tax Auditor
Identity and Tax Audit Warrant?
2
During the Audit, does the Tax Auditor firstly deliver the
Tax Audit Notification Letter?
3
Does the Tax Auditor explain the objectives and purposes of
the Audit?
4
Does the Tax Auditor inform you to enter room or space
that is deemed necessary?
5
Whether the Tax Auditor gave a written evidence of
borrowing on the loaned books, records, documents and/or
other data?
6
Does the Tax Auditor give the written notification to you
regarding the Audit Result in the form of SPHP?
7
Does the Tax Auditor provide opportunity to you to give a
response and explanation on the Audit findings?
8
Does the Tax Auditor explain to you regarding the Audit
Quality Assurance Team and the benefits for you?
9
Does the Tax Auditor give instruction to you regarding the
implementation of good bookkeeping?
10
Does the Tax Auditor return the files and documents within
the maximum period of 7 (seven) working days after the
Audit is completed and give you the receipt of return?
11
Does the Tax Auditor ask and promise you something in
connection with the Audit Decision?
12
In your opinion, do you think that the Tax Auditor has
performed the Audit duty in good manners?
13
Matters that you wish to convey:
1. ..
2. And so on.
Tax Audit Warrant:
Number
: ..
Date
: ..

YES

Taxpayer:
(.)

NO

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-9Your answers shall be sent to the Director of Audit and Collection or the Head of
the Regional Office of Directorate General of Tax.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 10 E. QUESTIONNAIRE OF THE IMPLEMENTATION OF OFFICE AUDIT TO EXAMINE


THE FULFILLMENT COMPLIANCE OF TAXATION OBLIGATIONS:
For improving the Audit quality and accountability, feedback in the form of
questionnaires answers is essential, we expect you could cooperate in the form of
your willingness to answer the following List of Questionnaires. Considering your
answer is essential for the Audit policy improvement in the future, it is expected
that you could give the answers in accordance with the actual situation.
Accordingly, for thank you for your cooperation.
NUMBER
QUESTION
1
During the Audit, does the Tax Auditor show Tax Auditor
Identity and Tax Audit Warrant?
2
During the Audit, does the Tax Auditor firstly deliver the
Summon?
3
Does the Tax Auditor explain the objectives and purposes of
the Audit?
4
Does the Tax Auditor give the written evidence of borrowing
on the borrowed books, records, documents and/or other
data?
5
Does the Tax Auditor give the written notification to you
regarding the Audit Result in the form of SPHP?
6
Does the Tax Auditor provide opportunity to you to give
response and explanation on the Audit findings?
7
Does the Tax Auditor explain to you regarding the Audit
Quality Assurance Team and the benefits for you?
8
Does the Tax Auditor give instruction to you regarding the
implementation of good bookkeeping?
9
Does the Tax Auditor return the files and documents within
the maximum period of 7 (seven) working days after the
Audit is completed and give the receipt of return?
10
Does the Tax Auditor ask and promise something in
connection with the Audit Decision?
11
In your opinion, do you think that the Tax Auditor has
performed the Audit duty in good manners?
12
Matters that you wish to convey:
1. ..
2. And so on.
Tax Audit Warrant :
Number
: ..
Date
: ..

YES

Taxpayer:
(.)

NO

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 11 Your answers shall be sent to the Director of Audit and Collection or the Head of
Regional Office of the Directorate General of Tax.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 12 F. QUESTIONNAIRE OF FIELD AUDIT IMPLEMENTATION FOR OTHER


PURPOSES:
For improving the Audit quality and accountability, feedback in the form of
questionnaires answers is essential, we expect you could cooperate in the form of
your willingness to answer the following List of Questionnaires. Considering that
your answer is essential for the Audit policy improvement in the future, it is
expected that you could give the answers in accordance with the actual situation.
Accordintly, thank you for your cooperation.
NUMBER
QUESTION
YES NO
1
During the Audit, does the Tax Auditor show Tax Auditor
Identification and Tax Audit Warrant?
2
During the Audit, does the Tax Auditor firstly deliver the
Tax Audit Notification Letter?
3
Does the Tax Auditor explain the objectives and purposes of
the Audit?
4
Does the Tax Auditor inform to you to enter room or space
that is deemed necessary?
5
Does the Tax Auditor give the written evidence of borrowing
on the borrowed books, records, documents and/or other
data?
6
Does the Tax Auditor return files and documents within the
maximum period of 7 (seven) working days after the Audit is
completed and give the receipt of return?
7
Does the Tax Auditor ask and promise something in
connection with the Audit Decision?
8
In your opinion, do you think that the Tax Auditor has
performed the Audit duty in good manners?
9
Matters that you wish to convey:
1. ..
2. And so on.
Tax Audit Warrant :
Number
: ..
Date
: ..

Taxpayer:
(.)

Your answers will be sent to the Director of Audit and Collection or the Head of the
Regional Office of the Directorate General of Tax.

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 13 -

G. QUESTIONNAIRE OF OFFICE AUDIT IMPLEMENTATION FOR OTHER


PURPOSES:
For improving the Audit quality and accountability, feedback in the form of
questionnaires answers is essential, we expect you could cooperate in the form of
your willingness to answer the following the List of Questionnaires. Considering
that your answer is essential for the Audit policy improvement in the future, it is
expected that you could give the answers in accordance with the actual situation.
Accordintly, thank you for your cooperation.
NUMBER
QUESTION
1
During the Audit, does the Tax Auditor show Tax Auditor
Identification and Tax Audit Warrant?
2
During the Audit, does the Tax Auditor firsly deliver the
Summon?
3
Does the Tax Auditor explain the objectives and purposes of
the Audit?
4
Does the Tax Auditor give the written evidence of borrowing
on the borrowed books, records, documents and/or other
data?
5
Does the Tax Auditor return the files and documents within
the maximum period of 7 (seven) working days after the
Audit is completed and give the receipt of return?
6
Does the Tax Auditor ask and promise something in
connection with the Audit Decision?
7
In your opinion, do you think that the Tax Auditor has
performed the Audit duty in manner?
8
Matters that you wish to convey:
1. ..
2. And so on.
Tax Audit Warrant:
Number
: ..
Date
: ..

YES

NO

Taxpayer:
(.)

Your answers shall be sent to the Director of Audit and Collection or the Head of
Directorate General of Taxation Regional Office.
Copy as
its original version
HEAD OF GENERAL BUREAU
u.b.
.
HEAD OF ADMINSTRATION SECTION

MINISTER OF FINANCE OF THE


REPUBLIC OF INDONESIA
Signed

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

- 14 OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
MARTOWARDOJO

AGUS

D.W.

APPENDIX X
REGULATION OF THE MINISTER OF FINANCE
NUMBER 17/PMK.03/2013
ON
AUDIT PROCEDURE

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

FORMAT OF DECREE OF THE ESTABLISHMENT OF FISCAL LOSS BASED ON


THE RE-AUDIT
MINISTRY OF FINANCE OF THE REPUBLIC OF INDONESIA
DIRECTORATE GENERAL OF TAX
.. (1)
DECREE OF THE DIRECTOR GENERAL OF TAX
NUMBER KEP- (2)
CONCERNING
DECREE OF THE ESTABLIHSMENT OF FISCAL LOSS BASED ON THE RE-AUDIT
Considering:

a. whereas based on the Tax Assessment Letter (3)


number .. (4) date .. (5), which is issued
from the Audit Results Report number . (6) date
. (7);
b. whereas pursuant to the Re-Audit Result Report number
.. (8) date (9);
c. whereas based on the considerations, as referred to in letter a
and letter b , it is necessary to stipulate the Decree of the
Director General of Tax concerning the Establishment of Fiscal
Loss Based on the Re-Audit;

Bearing In Mind : 1. Law Number 6 Year 1983 concerning General Provisions and
Tax Procedures (State Gazette of the Republic of Indonesia
Year 1983 Number 49, Supplement to the State Gazette of the
Republic of Indonesia Number 3262) as it has been several
times amended lastly with Law Number 16 Year 2009 (State
Gazette of the Republic Indonesia of 2009 Number 62,
Supplement to the State Gazette of the Republic of Indonesia
Number 4999);
2. Law Number 7 Year1983 concerning Income Tax (State
Gazette Year 1983 Number 50, Supplement to State Gazette
Number 3263) as it has been several times amended lastly
with Law Number 36 Year 2008 (State Gazette Year 2008
Number 133, Supplement to the State Gazette Number 4893);

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-23. Governmental Regulation Number 74 Year 2011 concerning


Procedures for Rights Implementation and Obligations
Compliance of Taxes (State Gazette of the Republic of
Indonesia Year 2011 Number 162, Supplement to the State
Gazette of the Republic of Indonesia Number 5268);
4. Regulation of the Minister of Finance No. /PMK.03/20
concerning Audit procedures;
5. (10);
BE IT HEREBY RESOLVED:
THE DECISION OF THE DIRECTOR GENERAL OF TAXATION
CONCERNING FISCAL LOSS DETERMINATION BASED ON THE
RE-AUDIT.
FIRST:
Determining that the amount of fiscal loss for the Fiscal Year of
. (11) over the Taxpayer .. (12), TIN
. (13), Address .. (14) pursuant to the
Re-Audit becomes the amount of IDR .. (15),
with the detail as follows:
Description
Before (IDR)
Added/ (Reduced)
Becoming (IDR)
(IDR)
(16)
(17)
(18)
a. Income
b. Costs
c. Fiscal loss
amount
Amount in words: .
(19)
To enact:

SECOND:

This Decree of the Director General shall come into force on the
date of the enactment.
The copy of this Director General Decision shall be delivered to:
1. ..
2. .
3. .. and so on (20)
., (21)
On behalf of DIRECTOR
GENERAL OF TAX
, (22)

NIP (23)

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-3FILLING INSTRUCTION OF DECREE OF THE ESTABLIHSMENT OF FISCAL LOSS


BASED ON THE RE-AUDIT
Number (1)
Number (2)
Number (3)

: Filled with Tax Service Office in which the Taxpayer is registered.


: Filled with number of the decision letter.
: Filled with type of the tax assessment letter that has been issued
on the Income Tax for Fiscal Year that is conducted the Re-Audit.
Number (4) : Filled with number of the tax assessment letter that has been
issued on the Income Tax for Fiscal Year that is conducted the ReAudit.
Number (5) : Filled with date of the tax assessment letter that has been issued
on the Income Tax for Fiscal Year that is conducted the Re-Audit.
Number (6) : Filled with number of the LHP as a basis for the issuance of tax
assessment letter.
Number (7) : Filled with date of the LHP as a basis for the issuance of tax
assessment letter.
Number (8) : Filled with number of the Re-Audit LHP.
Number (9) : Filled with date of the Re-Audit LHP.
Number (10) : Filled with the prevailing Decree of Director General of Tax
concerning the delegation of authority of the Director General of
Tax to the Officials in the Directorate General of Tax.
Number (11) : Filled with Fiscal Year to be be Re-Audited.
Number (12) : Filled with name of Taxpayer.
Number (13) : Filled with Tax Identification Number.
Number (14) : Filled with address of Taxpayer.
Number (15) : Filled with the amount of fiscal loss of which is established based
on the Re-Audit.
Number (16) : Filled with amount of Income, costs, and fiscal loss according to the
LHP that becomes the basis of tax assessment letter that have been
issued.
Number (17) : Filled with the amount of addition/ reduces of Income, costs, and
fiscal loss based on the Re-Audit.
Number (18) : Filled with the amount of Income, costs, and fiscal loss of which is
determined based on the Re-Audit.
Number (19) : Filled with the amount of the determined fiscal loss that stated in
word.
Number (20) : Filled with the parties that will be given a copy of the decision letter
of fiscal loss determination.
Number (21) : Filled with name of city and date when the decision letter is issued.
Number (22) : Filled with position name of the official who signs the decree.
Number (23) : Filled with signature, name, NIP, and position stamp of the official
who signs the decision letter.
Copy as its
original version

MINISTER OF FINANCE OF THE


REPUBLIC OF INDONESIA

MINISTER OF FINANCE
OF THE REPUBLIC OF INDONESIA

-4HEAD OF GENERAL BUREAU


u.b.
.
HEAD OF ADMINSTRATION SECTION
OF THE MINISTRY
Signed and stamped.
GIARTO
NIP 195904201984021001
MARTOWARDOJO

Signed

AGUS

D.W.