Peraturan Menteri Keuangan Nomor - 18 - PMK.03 - 2021 (ENGLISH)

MINISTER OF FINANCE OF THE REPUBLIC OF
INDONESIA REGULATION
NUMBER 18/PMK.03/2021
CONCERNING
THE IMPLEMENTATION OF LAW NUMBER 11 OF 2020 CONCERNING JOB

CREATION IN THE FIELD OF INCOME TAX, VALUE ADDED TAX AND SALES
TAX ON LUXURY GOODS AS WELL AS GENERAL PROVISIONS AND TAX
PROCEDURES
BY THE GRACE OF ALMIGHTY GOD

THE MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA,
Considering
a. that to implement the provisions under Article 2 paragraph (4), Article 4 paragraph (1d)
and Article 4 paragraph (3) subparagraph f, subparagraph o and subparagraph p of Law
Number 7 of 1983 concerning Income Tax as amended several times, last amended by
Law Number 11 of 2020 concerning Job Creation, it is necessary to further regulate the
provisions in the field of Income Tax to support ease of doing business;
b. that to implement the provisions under Article 9 paragraph (13) subparagraph a,

subparagraph b, subparagraph c and subparagraph e as well as Article 13 paragraph
(5a) and paragraph (8) of Law Number 8 of 1983 concerning Value Added Tax on
Goods and Services and Sales Tax on Luxury Goods as amended several times, last
amended by Law Number 11 of 2020 concerning Job Creation, it is necessary to
regulate the provisions on Value Added Tax and Sales Tax on Luxury Goods to support
ease of doing business;
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c. that to implement the provisions under Article 9 paragraph (3a), Article 9 paragraph (4),
Article 13 paragraph (6), Article 14 paragraph (6), Article 15 paragraph (5), Article 17B
paragraph (1a), Article 27B paragraph (8) and Article 44B paragraph (3) of Law Number
6 of 1983 concerning General Provisions and Tax Procedures as amended several
times, last amended by Law Number 11 of 2020 concerning Job Creation, it is
necessary to regulate the provisions on general provisions and tax procedures to
support ease of doing business;
d. that based on the considerations referred to in letter a, letter b and letter c, it is

necessary to stipulate a Minister of Finance Regulation concerning the Implementation
of Law Number 11 of 2020 concerning Job Creation in the Field of Income Tax, Value
Added Tax and Sales Tax on Luxury Goods as well as General Provisions and Tax
Procedures;
In view of
1. Article 17 paragraph (3) of the 1945 Constitution of the Republic of Indonesia;
2. Law Number 6 of 1983 concerning General Provisions and Tax Procedures Regulations
(State Gazette of the Republic of Indonesia of 1983 Number 49, Supplement to the
State Gazette of the Republic of Indonesia Number 3262) as amended several times,
last amended by Law Number 11 of 2020 concerning Job Creation (State Gazette of
the Republic of Indonesia of 2020 Number 245, Supplement to the State Gazette of
the Republic of Indonesia Number 6573);
3. Law Number 7 of 1983 concerning Income Tax (State Gazette of the Republic of
Indonesia of 1983 Number 50, Supplement to the State Gazette of the Republic of
Indonesia Number 3263) as amended several times, last amended by Law Number 11
of 2020 concerning Job Creation (State Gazette of the Republic of Indonesia of 2020
Number 245, Supplement to the State Gazette of the Republic of Indonesia Number
6573);
4. Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales
Tax on Luxury Goods (State Gazette of the Republic of Indonesia of 1983 Number 51,
Supplement to the State Gazette of the Republic of Indonesia Number 3264) as
amended several times, last amended by Law Number 11 of 2020 concerning Job
Creation (State Gazette of the Republic of Indonesia of 2020 Number 245, Supplement
to the State Gazette of the Republic of Indonesia Number 6573);

5. Law Number 39 of 2008 concerning State Ministries (State Gazette of the Republic of
Indonesia Number 4916);
6. Law Number 11 of 2020 concerning Job Creation (State Gazette of the Republic of
Indonesia Number 6573);
7. Presidential Regulation Number 57 of 2020 concerning the Ministry of Finance (State

Gazette of the Republic of Indonesia of 2020 Number 98);
8. Minister of Finance Regulation Number 145/PMK.03/2012 concerning Procedures for

the Issuance of Notice of Tax Assessment and Notice of Tax Collection (Official Gazette
of the Republic of Indonesia of 2012 Number 902) as amended by the Minister of
Finance Regulation Number 183/PMK.03/2015 concerning the Amendment to Minister
of Finance Regulation Number 145/PMK.03/2012 concerning Procedures for the
Issuance of Notice of Tax Assessment and Notice of Tax Collection (Official Gazette of
the Republic of Indonesia of 2015 Number 1467);

Audits (Official Gazette of the Republic of Indonesia of 2013 Number 47) as amended
by the Minister of Finance Regulation Number 184/PMK.03/2015 concerning the
Amendment to Minister of Finance Regulation Number 17/PMK.03/2013 concerning
Procedures for Audits (Official Gazette of the Republic of Indonesia of 2015 Number
1468);

Preliminary Tax Crime Investigations (Official Gazette of the Republic of Indonesia of
2014 Number 1951);

the Payment and Remittance of Taxes (Official Gazette of the Republic of Indonesia of
2014 Number 1973);
12. Minister of Finance Regulation Number 243/PMK.03/2014 concerning Tax Returns

(Official Gazette of the Republic of Indonesia of 2014 Number 1974) as amended by
the Minister of Finance Regulation Number 9/PMK.03/2018 concerning the
Tax Returns (Official Gazette of the Republic of Indonesia of 2018 Number 180);
13. Minister of Finance Regulation Number 55/PMK.03/2016 concerning Applications for

the Termination of Tax Crime Investigations for Tax Revenue Purposes (Official Gazette
of the Republic of Indonesia of 2016 Number 538);

14. Minister of Finance Regulation Number 217/PMK.01/2018 concerning the Organization
and Work Procedures of the Ministry of Finance (Official Gazette of the Republic of
Indonesia of 2018 Number 1862) as amended several times, last amended by Minister
of Finance Regulation Number 229/PMK.01/2019 concerning the Second Amendment
to the Minister of Finance Regulation Number 217/PMK.01/2018 concerning the
Organization and Work Procedures of the Ministry of Finance (Official Gazette of the
Republic of Indonesia of 2019 Number 1745);
HAS DECIDED:
To stipulate
MINISTER OF FINANCE REGULATION CONCERNING THE IMPLEMENTATION OF LAW NUMBER

11 OF 2020 CONCERNING JOB CREATION IN THE FIELD OF INCOME TAX, VALUE ADDED TAX
AND SALES TAX ON LUXURY GOODS AS WELL AS GENERAL PROVISIONS AND TAX
PROCEDURES.
CHAPTER I
GENERAL PROVISIONS
Article 1
Referred to herein this Minister of Finance Regulation:
1. Income Tax Law, hereinafter referred to as the PPh Law, is Law Number 7 of 1983
concerning Income Tax as amended several times, last amended by Law Number
11 of 2020 concerning Job Creation.
2. Value Added Law, hereinafter referred to as the VAT Law, is Law Number 8 of 1983
concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods
as amended several times, last amended by Law Number 11 of 2020 concerning Job
Creation.
3. General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is
Law Number 6 of 1983 concerning General Provisions and Tax Procedures as
Creation.

4. Income Tax, hereinafter abbreviated to PPh, is Income Tax referred to in the Income
Tax Law.
5. Value Added Tax, hereinafter abbreviated to VAT, is Value Added Tax referred to in the
VAT Law.
6. Sales Tax on Luxury Goods, hereinafter abbreviated to STLGs, is Sales Tax on Luxury
Goods referred to in the VAT Law.
7. Land and Building Tax, hereinafter abbreviated to PBB, is Land and Building Tax
referred to in Law Number 12 of 1985 concerning Land and Building Tax as amended
by Law Number 12 of 1994.
8. Taxpayer is any individual or entity, comprising a taxpayer and withholding agent having
tax rights and obligations pursuant to statutory tax provisions.
9. Tax Year is a period of 1 (one) calendar year unless a Taxpayer adopts an accounting
year that is different from the calendar year.
10. Taxable Period is a period used as the basis for a Taxpayer to calculate, remit and file
taxes payable in a certain period as stipulated by the General Provisions and Tax
Procedures Law.
11. Taxpayer Identification Number, hereinafter abbreviated to TIN, is a number issued to

Taxpayers as a means of tax administration that is used as a personal identity or
Taxpayer identity in conducting their tax rights and obligations.
12. State Revenue Transaction Number, hereinafter abbreviated to NTPN, is the number of
proof of payment or remittance to the state treasury issued through the state revenue
module or by the state revenue system managed by the Directorate General of
Treasury.
13. Indonesian Citizen, hereinafter abbreviated to WNI, is a native Indonesian person or a

person of another nationality who has been legalized as an Indonesian Citizen
pursuant to statutory provisions on the citizenship of the Republic of Indonesia.
14. Foreign Citizen, hereinafter abbreviated to WNA, is anyone who is not an Indonesian
Citizen.
15. Certificate of Indonesian Citizens Fulfiling the Requirements to Become Resident

Taxpayers is a letter issued by the Head of the Tax Office on behalf of the Director
General of Taxes explaining that an Indonesian Citizen fulfils the requirements to be a
non-resident tax subject.

16. Tax Treaty, hereinafter abbreviated to P3B, is an agreement between the Government
of Indonesia and the government of a treaty partner or partner jurisdiction to prevent
double taxation and tax evasion.
17. Employer is a legal entity or another entity that employs a Foreign Citizen by paying
wages or remunerations in other forms.
18. Dividend is the share of profits received or accrued by shareholders.
19. Net Income After Tax is comprehensive net income after tax.
20. Retained Earnings is the accumulation of Net Income After Tax that is not distributed to
the shareholders in the form of Dividends which are used to finance various company
interests.
21. Hajj Financial Management Agency, hereinafter abbreviated to BPKH, is an institution

that carries out the financial management of hajj pursuant to statutory provisions on
the financial management of hajj.
22. Hajj Fees, hereinafter abbreviated to BPIH, are an amount of funds that must be paid by
a citizen who will carry out hajj.
23. Special Hajj Fees, hereinafter referred to as Special BPHI, are an amount of funds that
must be paid by a citizen who will carry out special hajj.
24. Customs Area is the territory of the Republic of Indonesia which includes land, waters
and airspace above it as well as certain places in the Exclusive Economic Zone and the
continental shelf in which the Law that stipulates customs is applicable.
25. Tax Base is the amount of Selling Price, Considerations, Import Value, Export Value or
other values used as the basis for calculating tax payable.
26. Taxable Goods, hereinafter abbreviated to BKP, are goods subject to tax pursuant to
the VAT Law.
27. Taxable Services, hereinafter abbreviated to JKP, services subject to tax pursuant to
the VAT Law.
28. Entrepreneur is any individual or entity in whatever form that in its course of business
or work produces goods, imports goods, exports goods, conducts trading business,
utilizes intangible goods from outside the Customs Area, conducts service businesses
or utilizes services from outside the Customs Area.

29. Taxable Persons for VAT Purposes, hereinafter abbreviated to PKP, are Entrepreneurs
supplying Taxable Goods and/or Taxable Services subject to tax pursuant to the VAT
Law.
30. Taxable Persons for VAT Purposes that Have Not Performed Any Supply are Taxable
Persons for VAT Purposes that have not performed supplies of Taxable Goods,
supplies of Taxable Services, exports of Taxable Goods, and/or exports of Taxable
Services.
31. Tax Office, hereinafter abbreviated to KPP, is an office within the Directorate General of
Taxes where Taxpayers are registered, Taxable Persons for VAT Purposes are
registered and/or Land and Building Tax objects are administered.
32. State Treasury Office, hereinafter abbreviated to KPPN, is a vertical agency of the
Directorate General of Treasury that obtains power of attorney from the State General
Treasurer to carry out some of the functions of the Proxy of State General Treasurer.
33. Tax Invoice is proof of tax collection by Taxable Persons for VAT Purposes supplying
Taxable Goods or Taxable Services.
34. Input VAT is VAT that should have been paid by Taxable Persons for VAT Purposes due
to an acquisition of Taxable Goods and/or acquisition of Taxable Services and/or
utilization of intangible Taxable Goods from outside the Customs Area and/or utilization
of Taxable Services from outside the Customs Area and/or imports of Taxable Goods.
35. Output VAT is VAT payable which must be collected by Taxable Persons for VAT
Purposes performing supplies of Taxable Goods, supplies of Taxable Services, exports
of tangible Taxable Goods, exports of intangible Taxable Goods and/or exports of
Taxable Services.
36. Tax Payment Slip is a receipt of tax payment or remittance using a specific form or
other means to the state treasury, through a place of payment appointed by the
Minister of Finance.
37. Electronic Information is one or a set of electronic data, including but not limited to
writing, sound, pictures, maps, designs, photographs, electronic data interchange
(EDI), electronic mail, telegram, telex, telecopy or the like, letters, signs, numbers,
access codes, symbols or processed perforations that have meaning or are
comprehensible by people who are able to understand them.

38. Electronic Signature is a signature consisting of Electronic Information that is attached,
associated or related to other Electronic Information which is used as a means of
verification and authentication.
39. Electronic Commerce is a trade in which transactions are carried out through a set of
electronic devices and procedures.
40. Tax Liability is outstanding tax, including administrative penalties in the form of interest,
fines or surcharges as stated in the notice of tax assessment or similar letters
pursuant to statutory tax provisions.
41. Interest Compensation Decision Letter, hereinafter abbreviated to SKPIB, is a decision

letter that determines the amount of interest compensation granted to a Taxpayer.
42. Calculation of Interest Compensation Decision Letter, hereinafter abbreviated to

SKPPIB, is a decision letter used as the basis for calculating interest compensation in
an Interest Compensation Decision Letter against the Tax Liability and/or taxes that will
be payable.
43. Interest Compensation Payment Order, hereinafter abbreviated to SPMIB, is a letter

issued by the Head of the Tax Office on behalf of the Minister of Finance to pay interest
compensation to a Taxpayer.
44. Preliminary Refunds Decision Letter, hereinafter abbreviated to SKPKPP, is a decision

letter used as the basis for issuing a Tax Overpayment Refund Order.
45. Fund Disbursement Order, hereinafter abbreviated to SP2D, is a letter issued by the
Head of the State Treasury Office as the Proxy of the State General Treasurer to carry
out expenditures borne by the State Budget based on the Interest Compensation
Payment Order.
46. Closing Conference is a discussion between a Taxpayer and tax auditors on audit
findings, the results of which are stated in the minutes of the closing conference,
which are signed by both parties and contain corrections to the principal tax payable,
either approved or disapproved and the calculation of administrative penalties.
47. Computer Data Archives, hereinafter abbreviated to ADK, are data archives in softcopy
form that are stored in digital storage media.

CHAPTER II
INCOME TAX
Section One
Requirements of Individual Tax Subjects
Article 2
(1) An individual constituting a resident taxpayer is an Indonesian Citizen or a Foreign

Citizen who:
a. resides in Indonesia;
b. has been present in Indonesia for more than (one hundred and eighty-three)
days within any 12 (twelve) months period; or
c. has been residing in Indonesia within a particular Tax Year and intends to reside
in Indonesia.
(2) An individual who resides in Indonesia referred to in paragraph (1) subparagraph a is an

individual who:
a. resides in a place in Indonesia that:
1. is held or can be accessed at any time;
2. is owned, rented or available to be used; and
3. is not merely a place of transit for the individual;
b. has a center of vital interests in Indonesia that is used by the individual as a

center for personal, social, economic and/or financial activities or affairs in
Indonesia; or
c. carries out daily habits or activities in Indonesia, including activities that constitute
interests or hobbies.
(3) The period of 183 (one hundred and eighty-three) days referred to in paragraph (1)
subparagraph b is determined by calculating the length of time an individual is present
in Indonesia within any 12 (twelve) months period, either consecutively or
intermittently. in which part of the day is calculated in full as 1 (one) day.

(4) An individual tax subject is deemed to intend to reside in Indonesia as referred to in
paragraph (1) subparagraph c may be proven by documents in the form of:
a. Permanent Stay/Resident Permit Card (KITAP);
b. Visa for Temporary Resident Permit (VITAS) with a validity period of more than 183
(one hundred and eighty-three) days;
c. Temporary Stay Permit (ITAS) with a validity period of more than 183 (one
hundred and eighty-three) days;
d. a contract or agreement to perform work, business or activities in Indonesia for

more than 183 (one hundred and eighty-three) days; or
e. other documents that may indicate the intention to reside in Indonesia, such as a
residential rental agreement for more than 183 (one hundred and eighty-three)
days or documents showing the transfer of a family member.
Article 3
(1) An individual constituting a non-resident taxpayer is:
a. an individual who does not reside in Indonesia;
b. a Foreign Citizen who has been present in Indonesia for not more than 183 (one
hundred and eighty-three) days within any 12 (twelve) months period; or
c. an Indonesian Citizen who is outside Indonesia for more than 183 days (one
hundred and eighty-three) within any 12 (twelve) months period and fulfills the
following requirements:
1. permanently residing in a place outside Indonesia that is not a place of

transit;
2. having a center of vital interests that shows personal, economic and/or

social relations outside Indonesia, which can be proven by:
a) a husband or wife, children and/or next of kin residing outside

Indonesia;
b) the income is sourced from outside Indonesia; and/or
c) being a member of a religious, educational, social and/or community

organization recognized by the state government;

3. a place of habitual abode;
4. becoming a resident taxpayer of another country or jurisdiction; and/or
5. other certain requirements.
(2) The requirements referred to in paragraph (1) subparagraph c number 1, number 2

and number 3 are fulfiled in stages under the following provisions:
a. the requirement of residing in a place outside Indonesia referred to in paragraph

(1) subparagraph c number 1 is a requirement that must be fulfiled;
b. in the event that the Indonesian Citizen who is outside Indonesia for more than
183 (one hundred and eighty-three) days within any 12 (twelve) months period
has fulfiled the requirements referred to in the requirement of the center of vital
interests of subparagraph a, the requirements of the center of vital interests and
a place of habitual abode outside Indonesia referred to in paragraph (1)
subparagraph c number 2 and number 3 do not have to be fulfiled insofar as the
Indonesian Citizen concerned no longer fulfils the requirements of residing in
Indonesia referred to in Article 2 paragraph (2) subparagraph a;
c. in the event that the person concerned fulfils the requirement of residing in a
place outside Indonesia referred to in paragraph (1) subparagraph c number 1 or
residing in Indonesia referred to in Article 2 paragraph (2) subparagraph a, the
provisions referred to in subparagraph b do not apply and the fulfilment of the
requirements shall be continued based on the requirement of the center of vital
interests referred to in paragraph (1) subparagraph c number 2;
d. in the event that the fulfilment of the requirements proceeds as referred to in

subparagraph c and the Indonesian Citizen concerned only has a center of vital
interests outside Indonesia as referred to in paragraph (1) subparagraph c
number 2, the requirement of the place of habitual abode referred to in
paragraph (1) subparagraph c number 3 does not have to be fulfiled; and
e. in the event that the person concerned fulfils the requirements of residing and
center of vital interests outside Indonesia as referred to in paragraph (1)
subparagraph c number 1 and number 2 and also fulfil the requirements of
residing and a center of vital interests in Indonesia as referred to in Article 2
paragraph (2) subparagraph a and subparagraph b, the provisions referred to in
subparagraph d do not apply and the fulfilment of the requirements shall be
continued based on the requirements of a place of habitual abode outside
Indonesia referred to in paragraph (1) subparagraph c number 3.

(3) The requirements referred to in paragraph (1) subparagraph c number 4 and number 5
are requirements that must be fulfiled.
(4) The requirements of tax residency referred to in paragraph (1) subparagraph c number
4 are fulfiled in the event that an Indonesian Citizen becomes a resident taxpayer of
another country or jurisdiction which may be proven by a certificate of domicile or other
documents showing the tax residency from the tax authorities of the other country or
jurisdiction with the following requirements:
a. using English;
b. at least including information regarding:
1. the name of the Indonesian Citizen;
2. date of issuance;
3. validity period; and
4. name and signed or given a sign equivalent to a signature by the

competent authority as per the prevalence in the country or jurisdiction
concerned; and
c. the period referred to in subparagraph b number 3 expires no later than 6 (six)

months prior to the application for determination of the tax residency to the
Director General of Taxes.
(5) Other certain requirements referred to in paragraph (1) subparagraph c number 5 are:
a. having completed tax obligations on all income received or accrued insofar as the
Indonesian Citizen constitutes a resident taxpayer; and
b. having obtained a Certificate of Indonesian Citizens Fulfiling the Requirements to

Become Resident Taxpayers issued by the Director General of Taxes.
Article 4
(1) To obtain the certificate referred to in Article 3 paragraph (5) subparagraph b, the
Indonesian Citizen referred to in Article 3 paragraph (1) subparagraph c must:

a. apply for the determination of tax residency stating that the Indonesian Citizen
fulfils the requirements as a non-resident taxpayer referred to in Article 3
paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and
paragraph (5) subparagraph a; and
b. attach documents that may prove the fulfilment of the requirements referred to in
Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph
(4) and paragraph (5) subparagraph a.
(2) The application referred to in paragraph (1) is submitted by an electronic application

through certain channels stipulated by the Director General of Taxes.
(3) In the event that certain channels referred to in paragraph (2) are not yet available, the
application may be submitted in writing:
a. directly; or
b. by post or a forwarder or courier service company with proof of postage, to the

Tax Office where the Taxpayer is registered.
(4) The Head of the Tax Office on behalf of the Director General of Taxes, based on
verification results, issues:
a. Certificate of Indonesian Citizens Fulfiling the Requirements to Become Resident

Taxpayers in the event that the Indonesian Citizen has fulfiled the provisions in
Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph
(4) and paragraph (5); or
b. a letter of rejection of the application in the event that the Indonesian Citizen
does not fulfil the provisions in Article 3 paragraph (1) subparagraph c, paragraph
(2), paragraph (3), paragraph (4) and paragraph (5),
within a maximum period of 30 (thirty) days after the application referred to in

paragraph (1) is received in full.
(5) In the event that the deadline of 30 (thirty) days referred to in paragraph (4) has
elapsed and the Head of the Tax Office on behalf of the Director General of Taxes has
not made a decision, the Indonesian Citizen’s application is deemed accepted.
(6) The Head of the Tax Office on behalf of the Director General of Taxes issues the
Certificate of Indonesian Citizens Fulfiling the Requirements to Become Resident
Taxpayers within a maximum period of 5 (five) days after the deadline referred to in
paragraph (4) elapses.
(7) The provisions on the format of documents in the form of:

a. the application referred to in paragraph (1) subparagraph a;
b. Certificate of Indonesian Citizens Fulfiling the Requirements to Become Resident

Taxpayers referred to in paragraph (4) subparagraph a; and
c. the letter of rejection of the application referred to in paragraph (4) subparagraph

b, are listed in Appendix I which constitutes an integral part of this Ministerial
Regulation.
(8) In the event that in the future, data and/or information is found that tax obligations
have not been or have not been fully fulfiled by the Indonesian Citizen who fulfils the
requirements referred to in Article 3 paragraph (1) subparagraph c, paragraph (2),
paragraph (3), paragraph (4) and paragraph (5), the Director General of Taxes may
issue tax assessments pursuant to statutory tax provisions.
Article 5
(1) The Indonesian Citizen referred to in Article 3 paragraph (1) subparagraph c is treated
as an individual leaving Indonesia for good as referred to in Article 2A of the Income Tax
Law and becomes a non-resident taxpayer since leaving Indonesia.
(2) An Indonesian Citizen who at the time of leaving Indonesia can show that he/she has
the intention of becoming a non-resident taxpayer pursuant to the provisions under
Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and
paragraph (5), may apply to be stipulated as a non-effective Taxpayer when leaving
Indonesia pursuant to statutory provisions in the field of general provisions and tax
procedures.
(3) The application to be stipulated as a non-effective Taxpayer referred to in paragraph

(2) shall be submitted by the Taxpayer through:
a. the Tax Office where the Taxpayer is registered;
b. the Tax Services, Dissemination and Consultation Service Office located within
the working area of the Tax Office where the Taxpayer is registered; or
c. certain channels stipulated by the Director General of Taxes.
(4) The application to be stipulated as a non-effective Taxpayer referred to in paragraph

(2) must be proven by attaching supporting documents that can prove the intention
referred to in paragraph (2) and the fulfilment of tax obligations.

(5) The Indonesian Citizen referred to in paragraph (2) must continue to fulfil certain
requirements referred to in Article 3 paragraph (1) subparagraph c, paragraph (2),
paragraph (3), paragraph (4) and paragraph (5) in the event that he/she has actually
been outside Indonesia for more than 183 (one hundred and eighty-three) days within
any 12 (twelve) months period by applying as referred to in Article 4 paragraph (1).
Article 6
(1) The Indonesian Citizen referred to in Article 3 paragraph (1) subparagraph c and Article
5 paragraph (2) who does not receive or accrue income sourced from Indonesia are
not subject to Income Tax in Indonesia.
(2) In the event that the Indonesian Citizen referred to in paragraph (1) receives or
accrues income sourced from Indonesia, such income is subject to Income Tax
pursuant to statutory tax provisions applicable to non-resident taxpayers.
(3) In the event that the Indonesian Citizen referred to in Article 5 paragraph (2) in the
further is actually known to not fulfil the requirements as a non-resident taxpayer as
referred to in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3),
paragraph (4) and paragraph (5) or does not implement the provisions referred to in
Article 5 paragraph (5), the said Indonesian Citizen:
a. the stipulation as a non-effective Taxpayer becomes nullified;
b. remains as a resident taxpayer; and
c. is liable to taxes pursuant to statutory tax provisions applicable to resident

taxpayers.
(4) In the event that the Indonesian Citizen referred to in paragraph (3) is subject to the
withholding of Article 26 Income Tax of the Income Tax Law from the stipulation as a
non-effective Taxpayer until the nullification as a non-effective Taxpayer, the said Article
26 Income Tax is creditable in calculating tax payable for Tax Year concerned.

Section Two
Certain Skill Criteria and Procedures for the Imposition of Income Tax
for Foreign Citizens
Article 7
(1) The income stipulated under Article 4 paragraph (1) of the Income Tax Law, either
sourced from Indonesia or from outside Indonesia, is subject to Income Tax pursuant
to statutory provisions in the field of Income Tax.
(2) Excluded from the provisions referred to in paragraph (1), a Foreign Citizen who
constitutes a resident taxpayer as referred to in Article 2 is subject to Income Tax only
on income received or accrued from Indonesia under the following conditions:
a. having certain skills; and
b. valid for 4 (four) Tax Years since he/she becomes a resident taxpayer.
(3) Included in the definition of income received or accrued from Indonesia referred to in
paragraph (2) is income received or accrued by a Foreign Citizen in connection with
work, services or activities in Indonesia in whatever name and form paid outside
Indonesia.
(4) The provisions referred to in paragraph (2) do not apply to a Foreign Citizen taking
advantage of a Tax Treaty between the Government of Indonesia and the government
of the Tax Treaty partner or jurisdiction where the Foreign Citizen earns income from
outside Indonesia.
Article 8
(1) Foreign Citizens with certain skills referred to in Article 7 paragraph (2) subparagraph a
include foreign workers occupying certain positions and foreign researchers.
(2) Foreign Citizens with certain skills referred to in paragraph (1) employed by the
Employer, must fulfil the requirements concerning:
a. the employment of foreign workers who can occupy certain positions as

stipulated by the minister in charge of government affairs in the field of
manpower; or

b. foreign researchers appointed by the minister in charge of government affairs in
the field of research.
(3) Certain skill criteria referred to in paragraph (1) include:
a. foreign nationality;
b. having expertise in the fields of science, technology and/or mathematics, as

evidenced by:
1. certificate of expertise issued by an institution appointed by the

Government of Indonesia or the government of the foreign worker’s
country of origin;
2. education diploma; and/or
3. 5 (five) years of work experience at the minimum,
in the field of science or field of work as per the field of expertise; and
c. having the obligation to transfer knowledge.
(4) The provisions on certain positions referred to in paragraph (1) are listed in Appendix II
which constitutes an integral part of this Ministerial Regulation.
Article 9
(1) The period of 4 (four) Tax Years referred to in Article 7 paragraph (2) subparagraph b is
calculated from the time a Foreign Citizen becomes a resident taxpayer.
(2) If within this period of 4 (four) Tax Years referred to in paragraph (1), the Foreign Citizen
leaves Indonesia, the end of that period continues to be calculated from the time the
Foreign Citizen first constitutes a resident taxpayer.
Article 10
A Foreign Citizen may choose to be subject to Income Tax only on income received or
accrued in Indonesia or take advantage of the Tax Treaty between the Government of
Indonesia and the government of the treaty partner or partner jurisdiction where the Foreign
Citizen earns income from outside Indonesia.

Article 11
(1) A Foreign Citizen who chooses to be subject to Income Tax only on income received
or accrued from Indonesia as referred to in Article 7 paragraph (2) must apply to the
(2) The application referred to in paragraph (1) shall use the format listed in Appendix III
(3) The application referred to in paragraph (1) is submitted by an electronic application

through certain channels stipulated by the Director General of Taxes.
(4) In the event that the certain channels referred to in paragraph (3) are not yet available,
the application may be submitted in writing:
a. directly; or
b. by post or a forwarder or courier service company with proof of postage, to the

Tax Office where the Taxpayer is registered.
(5) The Head of the Tax Office on behalf of the Director General of Taxes, based on
verification results issues:
a. a letter of approval for the application for the imposition of Income Tax only on
income received or accrued from Indonesia, if the requirements referred to in
Article 8 are fulfiled; or
b. a letter of rejection of the application for the imposition of Income Tax only on
income received or accrued from Indonesia, if the requirements referred to in
Article 8 are not fulfiled,
within a maximum period of 10 (ten) working days after the application referred to in
paragraph (1) is received in full.
(6) The provisions on the format of documents in the form of:
a. the letter of approval of the application referred to in paragraph (5) subparagraph

a; and
b. the letter of rejection of the application referred to in paragraph (5) subparagraph

b,
are listed in Appendix IV which constitutes an integral part of this Ministerial Regulation.

Article 12
(1) Foreign Citizens file income through Annual Tax Returns for:
a. income received or accrued from Indonesia, if a letter of approval is issued for the
application for the imposition of Income Tax only on income received or accrued
from Indonesia as referred to in Article 11 paragraph (5) subparagraph a; or
b. income received or accrued from Indonesia and from outside Indonesia, if a letter
of rejection is issued for the application for the imposition of Income Tax only on
income received or accrued from Indonesia as referred to in Article 11 paragraph
(5) subparagraph b.
(2) Prior to filing income referred to in paragraph (1), the Foreign Citizen calculates income
pursuant to statutory provisions.
(3) The provisions on the calculation of the imposition of Income Tax only on income
received or accrued from Indonesia are listed in Appendix V which constitutes an
integral part of this Ministerial Regulation.
Article 13
(1) Foreign Citizens with certain skills who had constituted resident taxpayers before the
enactment of this Ministerial Regulation, may be subject to Income Tax only on income
received or accrued from Indonesia insofar as the following requirements are fulfiled:
a. the period of 4 (four) Tax Years referred to in Article 7 paragraph (2)

subparagraph b has not elapsed; and
b. applying as referred to in Article 11 paragraph (1).
(2) In the event that the application referred to in paragraph (1) subparagraph b is
approved, the imposition of Income Tax only on income received or accrued from
Indonesia is calculated from the enactment of Law Number 11 of 2020 concerning Job
Creation until the expiration of the period referred to in Article 7 paragraph (2)
subparagraph b.

Section Three
Criteria, Procedures and Certain Periods for Investments, Procedures
for the Exclusion from the Imposition of Income Tax on Dividends or
Other Income Excluded from Taxable Objects as Well as Changes in the
Threshold on Invested Dividends
Paragraph 1
Dividends Excluded from Income Tax Objects
Article 14
(1) Dividends that are excluded from Income Tax objects are Dividends sourced:
a. domestically; or
b. overseas,
received or accrued by a Taxpayer.
(2) The Taxpayer referred to in paragraph (1) constitutes a resident Taxpayer.
Article 15
(1) Domestically-sourced dividends referred to in Article 14 paragraph (1) subparagraph a

received or accrued by resident individual Taxpayers are excluded from Income Tax
objects provided that they must be invested in the territory of the Unitary State of the
Republic of Indonesia within a certain period.
(2) Domestically-sourced dividends referred to in Article 14 paragraph (1) subparagraph a

received or accrued by resident corporate Taxpayers are excluded from Income Tax
objects.
Article 16

(1) In the event that the Dividends referred to in Article 14 paragraph (1) subparagraph a
invested in the territory of the Unitary State of the Republic of Indonesia are less than
the total Dividends received or accrued by the resident individual Taxpayer, the
invested Dividends are excluded from the imposition of Income Tax.
(2) The difference of received or accrued Dividends less the invested Dividends referred
to in paragraph (1) is subject to Income Tax pursuant to statutory provisions.
Article 17
(1) Foreign-sourced Dividends referred to in Article 14 paragraph (1) subparagraph b

received or accrued by a Taxpayer referred to in Article 14 are excluded from Income
Tax objects.
(2) Foreign-sourced Dividends referred to in paragraph (1) are excluded from Income Tax
objects provided that they must be invested or used to support other businesses
within the territory of the Unitary State of the Republic of Indonesia within a certain
period.
(3) Foreign-sourced Dividends referred to in paragraph (1) are:
a. distributed Dividends sourced from a listed offshore company received or

accrued by the Taxpayer; or
b. distributed Dividends sourced from a non-listed offshore company as per the

proportion of share ownership.
Article 18
Distributed Dividends sourced from a listed offshore company referred to in Article 17

paragraph (3) subparagraph a are excluded from Income Tax objects in the amount of
Dividends invested in the territory of the Unitary State of the Republic of Indonesia within a
certain period.
Article 19

In the event that the Distributed Dividends sourced from a listed offshore company referred
to in Article 18 invested in the territory of the Unitary State of the Republic of Indonesia are
less than the Dividends received or accrued by the Taxpayer, the invested Dividends are
excluded from the imposition of Income Tax.
Article 20
The difference of the Dividends received or accrued by the Taxpayer less the invested
Dividends referred to in Article 19 is subject to Income Tax pursuant to statutory provisions.
Article 21
(1) In addition to fulfiling the requirements referred to in Article 17 paragraph (2),

distributed Dividends sourced from a non-listed offshore company referred to in Article
17 paragraph (3) subparagraph b, must be invested in the territory of the State Unitary
Republic of Indonesia within a certain period, by a minimum of 30% (thirty percent) of
Net Income After Tax.
(2) Dividends referred to in paragraph (1) must be invested before the Director General of
Taxes issues a notice of tax assessment on such Dividends in connection with the
application of the provisions referred to in Article 18 paragraph (2) of the Income Tax
Law.
(3) Dividends referred to in paragraph (1) which are invested after the Director General of
Taxes issues a notice of tax assessment on such Dividends in connection with the
application of provisions referred to in Article 18 paragraph (2) of the Income Tax Law,
such Dividends are not excluded from the imposition of Income Tax.
(4) Dividends referred to in paragraph (1) are Dividends sourced from Net Income After
Tax starting the 2020 Tax Year, received or accrued as of 2 November 2020.
Article 22

(1) In the event that the Dividends referred to in Article 21 paragraph (1) invested in the
territory of the Unitary State of the Republic of Indonesia are less than 30% (thirty
percent) of the total Net Income After Tax, the invested Dividends are excluded from
the imposition of Income Tax.
(2) The difference of 30% (thirty percent) of Net Income After Tax less the Dividends
invested in the territory of the Unitary State of the Republic of Indonesia referred to in
paragraph (1) is subject to Income Tax pursuant to Article 17 of the Income Tax Law.
(3) Residual Net Income After Tax less by Dividends invested in the territory of the Unitary
State of the Republic of Indonesia referred to in paragraph (1) after subtracted by the
difference referred to in paragraph (2), is not subject to Income Tax.
Article 23
(1) In the event that the Dividends referred to in Article 21 paragraph (1) invested in the
territory of the Unitary State of the Republic of Indonesia are more than 30% (thirty
percent) of the total Net Income After Tax, the invested Dividends are excluded from
the imposition of Income Tax.
(2) Residual Net Income After Tax less the Dividends invested in the territory of the Unitary
State of the Republic of Indonesia referred to in paragraph (1) is not subject to Income
Tax.
Article 24
(1) Dividends excluded from Income Tax objects referred to in Article 14 paragraph (1) are
Dividends distributed based on:
a. General Meeting of Shareholders; or
b. Interim Dividends pursuant to statutory provisions.
(2) General meeting of shareholders or interim Dividends referred to in paragraph (1)

include similar meetings and similar Dividend distribution mechanisms.

Paragraph 2
Other Income Excluded from Income Tax Objects
Article 25
(1) Other income excluded from Income Tax objects is other income sourced overseas
received or accrued by a Taxpayer.
(2) Other income referred to in paragraph (1) is:
a. income after tax from an overseas permanent establishment; or
b. foreign-sourced income not through a permanent establishment.
(3) Taxpayer referred to in paragraph (1) is a resident Taxpayer.
Article 26
(1) Income after tax from an overseas permanent establishment referred to in Article 25
paragraph (2) subparagraph a received or accrued by the Taxpayer is excluded from
Income Tax objects provided that it must be invested or used to support other
businesses in the territory of the Unitary State of the Republic of Indonesia within a
certain period.
(2) In addition to fulfiling the requirements referred to in paragraph (1), income after tax
from an overseas permanent establishment must be invested or used to support
other businesses in the territory of the Unitary State of the Republic of Indonesia within
a certain period, by a minimum of 30% (thirty percent) of Net Income After Tax.
Article 27
(1) In the event that income after tax from an overseas permanent establishment referred
to in Article 26 paragraph (2) invested in the territory of the Unitary State of the
Republic of Indonesia is less than 30% (thirty percent) of the total Net Income After
Tax, the invested income after tax from an overseas permanent establishment is

(2) The difference of 30% (thirty percent) of Net Income After Tax less the income after tax
from an overseas permanent establishment invested in the territory of the Unitary
State of the Republic of Indonesia referred to in paragraph (1) is subject to Income Tax
pursuant to Article 17 of the Income Tax Law.
(3) Residual Net Income After Tax less the income after tax from an overseas permanent
establishment invested in the territory of the Unitary State of the Republic of Indonesia
referred to in paragraph (1) and the difference referred to in paragraph (2) are not
subject to Income Tax.
Article 28
(1) In the event that the income after tax from an overseas permanent establishment
referred to in Article 26 paragraph (2) invested in the territory of the Unitary State of the
Republic of Indonesia is more than 30% (thirty percent) of the total Net Income After
Tax, the invested income after tax from the overseas permanent establishment is
(2) Residual Net Income After Tax less income after tax from an overseas permanent
establishment invested in the territory of the Unitary State of the Republic of Indonesia
referred to in paragraph (1) is not subject to Income Tax.
Article 29
(1) Foreign-sourced income not through a permanent establishment referred to in Article

25 paragraph (2) subparagraph b received or accrued by the Taxpayer is excluded
from Income Tax objects provided that it must be invested in the territory of the Unitary
State of the Republic of Indonesia within a certain period.
(2) In addition to fulfiling the requirements referred to in paragraph (1), foreign-sourced

income not through a permanent establishment must fulfil the following requirements:
a. the income is sourced from an overseas active business; and
b. does not constitute income from an offshore company;
(3) Foreign-sourced income not through a permanent establishment referred to in

paragraph (1) is foreign-sourced income from an overseas business.

Article 30
(1) In the event that foreign-sourced income not through a permanent establishment
referred to in Article 29 paragraph (1) invested in the territory of the Unitary State of the
Republic of Indonesia is less than the amount of other income received or accrued by
the Taxpayer, the invested foreign-sourced income not through a permanent
establishment is excluded from the imposition of Income Tax.
(2) The difference of foreign-sourced income not through a permanent establishment

received or accrued by the Taxpayer less by foreign-sourced income not through a
permanent establishment invested in the territory of the Unitary State of the Republic
of Indonesia referred to in paragraph (1) is subject to Income Tax pursuant to Article 17
of the Income Tax Law.
Paragraph 3
Foreign Tax Credit
Article 31
(1) To tax on income that has been paid or payable overseas on foreign-sourced foreign-
sourced Dividends referred to in Article 17 or other income sourced from overseas
referred to in Article 25 which is excluded from Income Tax objects, the following
provisions shall apply:
a. cannot be taken into account in the income tax payable;
b. cannot be charged as an expense or income deduction; and/or
c. tax overpayments are non-refundable.
(2) In the event that foreign-sourced Dividends or other income sourced from overseas
received or accrued by a Taxpayer are not fully invested in the territory of the Unitary
State of the Republic of Indonesia, the tax credit for withholding tax overseas is
calculated proportionally.

Article 32
The provisions on the calculation of exclusion from Income Tax objects referred to in Article
16, Article 19, Article 22, Article 27 and Article 30 are listed in Appendix VI which constitutes
an integral part of this Ministerial Regulation.
Paragraph 4
Certain Criteria, Procedures and Periods for Investments
Article 33
Investments referred to in Article 15, Article 17, Article 26 and/or Article 29 must fulfil certain
criteria, procedures and periods.
Article 34
Investments referred to in Article 15, Article 17, Article 26 and/or Article 29 are performed
according to the criteria for the forms of investment:
a. governments of the Republic of Indonesia and government sharia securities of the

Republic of Indonesia;
b. bonds or sharia bonds of State-Owned Enterprises whose trading is supervised by the

Financial Services Authority;
c. bonds or sharia bonds of financing institutions owned by the government whose

trading is supervised by the Financial Services Authority;
d. financial investment in tax payment banks, including Sharia banks;
e. bonds or sharia bonds of private companies whose trading is supervised by the

Financial Services Authority;
f. infrastructure investments through government cooperation with business entities;
g. real sector investment based on priorities determined by the government;

h. equity participation in companies newly established and domiciled in Indonesia as
shareholders;
i. equity participation in companies that have been established and domiciled in

Indonesia as shareholders;
j. cooperation with investment management institutions;
k. use to support other businesses in the form of loans to micro and small businesses
within the territory of the Unitary State of the Republic of Indonesia pursuant to
statutory provisions in the field of micro, small and medium enterprises; and/or
l. other forms of legitimate investments pursuant to statutory provisions.
Article 35
(1) Investments referred to in Article 34 subparagraph a to subparagraph e and

subparagraph l, are placed in investment instruments in financial markets:
a. debt securities, including medium-term notes;
b. sharia bonds;
c. shares;
d. participation units of mutual funds;
e. asset-backed securities;
f. participation units of real estate investment funds;
g. time deposits;
h. savings;
i. checking/current accounts;
j. futures contracts traded on futures exchanges in Indonesia; and/or
k. other financial market investment instruments, including insurance products

linked to investments, financing companies, pension funds or venture capital,
which are approved by the Financial Services Authority.
(2) Investments referred to in Article 34 subparagraph f to subparagraph k, are placed in

investment instruments outside financial markets:

a. infrastructure investments through government cooperation with business
entities;
b. real sector investments based on priorities stipulated by the government;
c. investments in property in the form of land and/or buildings erected thereon;
d. direct investments in companies in the territory of the Unitary State of the

Republic of Indonesia;
e. investments in precious metals in the form of gold bullion;
f. cooperation with investment management institutions;
g. use to support other businesses in the form of loans to micro and small
businesses within the territory of the Unitary State of the Republic of Indonesia
pursuant to statutory provisions in the field of micro, small and medium
enterprises; and/or
h. other legitimate forms of investments outside financial markets pursuant to

statutory provisions.
(3) Investments referred to in paragraph (2) subparagraph b and subparagraph d are

performed through the mechanisms of equity participation in a company in the form of
a limited liability company.
(4) Sectors constituting the government’s priority in real sector investments referred to in
paragraph (2) subparagraph b include sectors specified in the National Medium-Term
Development Plan.
(5) Property referred to in paragraph (2) subparagraph c does not include property
subsidized by the government.
(6) Precious metals referred to in paragraph (2) subparagraph e are 99.99% (ninety-nine
point ninety-nine percent) carat gold bullion.
(7) Gold bullion referred to in paragraph (6) is gold produced in Indonesia and is
accredited and certified by the Indonesian National Standard (SNI) and/or the London
Bullion Market Association (LBMA).
Article 36
(1) Investments referred to in Article 35 are performed no later than:

a. the end of the third month, for individual Taxpayers; or
b. the end of the fourth month, for corporate Taxpayers,
after the Tax Year ends, for the Tax Year in which the dividends or other income are
received or accrued.
(2) Investments referred to in Article 35 are performed for a minimum of 3 (three) Tax
Years as of the Tax Year the Dividends or other income are received or accrued.
(3) Investments referred to in Article 35 are not transferable, except in the form of
investments referred to in Article 35.
Paragraph 5
Procedures for the Exclusion of Imposition of Income Tax on Dividends
or Other Income
Article 37
(1) Exclusion from Income Tax objects of domestically-sourced Dividends referred to in

Article 14 paragraph (1) subparagraph a received or accrued by:
a. resident individual Taxpayers referred to in Article 15 paragraph (1); or
b. resident corporate Taxpayers referred to in Article 15 paragraph (2),
is carried out by filing domestically-sourced Dividends in the Annual Tax Return as

income not included as taxable objects.
(2) Domestically-sourced Dividends which are excluded from Income Tax objects referred
to in paragraph (1) shall not be subject to Income Tax withholding by the withholding
agent without a Withholding Exemption Certificate.
(3) Exclusion from Income Tax objects of foreign-sourced Dividends referred to in Article
14 paragraph (1) subparagraph b is carried out by filing foreign-sourced Dividends in
the Annual Tax Return as income not included as taxable objects.
Article 38

Exclusion from Income Tax objects for other income sourced from overseas referred to in
Article 25 is carried out by filing other income sourced from overseas in the Annual Tax
Return as income not included as taxable objects.
Article 39
Dividends or other income that does not fulfil the criteria for the forms of investments
referred to in Article 34, procedure referred to in Article 35 and investment period referred to
in Article 36, is subject to Income Tax payable when the Dividends or other income are
Article 40
(1) Income Tax payable on domestically-sourced Dividends referred to in Article 16

paragraph (2) and/or Article 39, must be self-remitted by resident individual Taxpayers
at a rate pursuant to statutory provisions.
(2) Income Tax referred to in paragraph (1) shall be remitted no later than the 15th
(fifteenth) of the following month after the Taxable Periods in which the Dividends are
(3) An individual Taxpayer that pays Income Tax payable referred to in paragraph (1) and
has received validation with State Revenue Transaction Number is deemed to have
filed a Periodic Income Tax Return according to the validation date.
Article 41
(1) Taxpayers referred to in Article 15 paragraph (1), Article 17 paragraph (1), and/or Article
25 paragraph (1) must submit investment realization reports.
(2) Reports referred to in paragraph (1) are submitted by electronic submission of the
reports through certain channels stipulated by the Director General of Taxes.

(3) In the event that certain channels referred to in paragraph (2) are not yet available, the
reports may be submitted in writing:
a. directly; or
b. by post or a forwarder or courier service company with proof of postage,
to the Tax Office where the Taxpayer is registered.
(4) Taxpayers must submit reports referred to in paragraph (1):
a. periodically no later than the end of the third month for individual Taxpayers or
the end of the fourth month for Corporate taxpayers after the Tax Year ends; and
b. submitted until the third year since the Tax Year the Dividends or other income
are received or accrued.
(5) The provisions on the format of documents in the form of investment realization
reports are listed in Appendix VII which constitutes an integral part of this Ministerial
Regulation.
(6) The provisions on report submission are listed in Appendix VIII which constitutes an
Paragraph 6
Changes in the Threshold of Invested Dividends
Article 42
In the event that there is a need for changes in the threshold of invested Dividends, the
threshold of invested Dividends may be changed.
Article 43
The provisions on changes to the threshold of invested Dividends referred to in Article 21

paragraph (1) are regulated by a Minister of Finance Regulation.

Section Four
Deposit Funds for Hajj Fees and/or Special Hajj Fees and Income from
the Development of Hajj Finances in Certain Fields or Financial
Instruments Excluded from Income Tax
Article 44
Revenues of Hajj Financial Management Agency include:
a. deposit funds for Hajj Fees and/or Special Hajj Fees;
b. the value of hajj financial benefits in the form of income from the development of hajj
finances;
c. efficiency fund for hajj;
d. people’s endowment fund; and/or
e. other legal and non-binding sources.
Article 45
(1) Deposit funds for Hajj Fees and/or special Hajj Fees referred to in Article 44
subparagraph a and income from the development of hajj finances in certain fields or
financial instruments referred to in Article 44 subparagraph b, received by the Hajj
Financial Management Agency, are excluded from Income Tax objects.
(2) Income from the development of hajj finances in certain fields or financial instruments
referred to in paragraph (1) in the form of:
a. yield from checking/current accounts, time deposits, certificates of deposit and

savings, at banks in Indonesia that conduct business based on sharia principles
as well as sharia securities issued by Bank Indonesia;
b. yield from sharia bonds, Government Sharia Securities and Sharia Treasury
Notes, which are traded and/or whose trade is reported on a stock exchange in
Indonesia;

c. domestically-sourced and foreign-sourced Dividends or other income in the form
of income after tax or income excluded from taxes or subject to 0% (zero
percent) tax from a permanent establishment or not through an overseas
permanent establishment;
d. share of profits received or accrued from holders of participation units of

collective investment contracts which may take the form of yield from sharia
mutual funds, collective investment contracts of asset-backed securities,
collective investment contracts of real estate investment funds, collective
investment contracts of infrastructure investment funds and/or collective
investment contracts based on similar sharia principles; and/or
e. sales of investments in the form of gold bullion or gold accounts managed by

sharia financial institutions,
pursuant to statutory provisions.
(3) Income referred to in paragraph (2) subparagraph a, subparagraph b, subparagraph c

and subparagraph d, as well as the purchase of gold bullion or gold accounts referred
to in paragraph (2) subparagraph e is excluded from Income Tax withholding.
(4) Exclusion from Income Tax withholding referred to in paragraph (3) is granted based on
an Income Tax withholding exemption certificate.
(5) To obtain the Income Tax withholding exemption certificate referred to in paragraph
(4), the Hajj Financial Management Agency must apply to the Head of the Tax Office
where the Hajj Financial Management Agency is registered.
(6) The provisions on the format of the application referred to in paragraph (5) are listed in
Appendix IX which constitutes an integral part of this Ministerial Regulation.
(7) Application referred to in paragraph (5) is submitted:
a. directly; or
b. by post or a forwarder or courier service company with proof of postage,
to the Tax Office where Hajj Financial Management Agency is registered.
(8) The Head of the Tax Office on behalf of the Director General of Taxes issues the
Income Tax withholding exemption certificate within a maximum period of 5 (five)
working days after the application referred to in paragraph (5) is received in full

(9) The provisions on the format of documents in the form of the certificate referred to in
paragraph (8) are listed in Appendix X which constitutes an integral part of this
Ministerial Regulation.
(10) The certificate referred to in paragraph (4) constitutes the basis for parties conducting
transactions with the Hajj Financial Management Agency not to withhold Income Tax as
referred to in paragraph (3).
(11) Income that is excluded as Income Tax objects referred to in paragraph (2) does not
include income from the development of people’s endowment fund referred to in
Article 44 subparagraph d.
(12) In the event that income from the development of people’s endowment fund referred
to in paragraph (11) subject to final Income Tax is not subject to Income Tax
withholding referred to in paragraph (3), the Hajj Financial Management Agency shall
self-remit Income Tax payable.
(13) Self-remittance of Income Tax payable referred to in paragraph (12) is carried out no
later than the 15th (fifteenth) of the following month after the Taxable Period the
income is received or accrued.
(14) In the event that Income Tax payable referred to in paragraph (13) has been remitted
and validated with a State Revenue Transaction Number, the Hajj Financial
Management Agency shall be deemed to have filed the Periodic Income Tax Return
according to the validation date.
(15) Income received or accrued by the Hajj Financial Management Agency other than:
a. deposit funds Hajj Fees and/or Special Hajj Fees referred to in paragraph (1);
b. income from the development of hajj finances referred to in paragraph (2); and
c. income from the development of people’s endowment fund on which the Income
Tax is self-remitted by the Hajj Financial Management Agency referred to in
paragraph (12),
is subject to Income Tax pursuant to statutory tax provisions.
Article 46
(1) Hajj Financial Management Agency must maintain separate bookkeeping if:
a. owning a business whose income is subject to final and non-final Income Tax; or

b. receiving or accruing income constituting a taxable and non-taxable object.
(2) Expenses related to income which:
a. are excluded from Income Tax objects referred to in Article 45 paragraph (1);
and/or
b. have been subject to final Income Tax, cannot be deducted from gross income.
(3) For joint costs related to income excluded from Income Tax objects referred to in
Article 45 paragraph (1), income from the development of the people’s endowment
funds on which Income Tax is self-remitted by the Hajj Financial Management Agency
referred to in Article 45 paragraph (12) and income referred to in Article 45 paragraph
(15), which cannot be separated in the context of Taxable Income calculation, the
expensing is allocated proportionally;
Article 47
(1) The provisions referred to in Article 45 paragraph (1) are effective as of the date of
promulgation of Law Number 11 of 2020 concerning Job Creation.
(2) For income referred to in Article 45 paragraph (1) which has been subject to final
Income Tax withholding from the date of the promulgation of Law Number 11 of 2020
concerning Job Creation, the Hajj Financial Management Agency may apply for tax
refunds that should not otherwise be payable.
(3) Procedures for the application for tax refunds that should not otherwise be payable
referred to in paragraph (2) are carried out pursuant to the Minister of Finance
Regulation concerning tax refunds that should not otherwise be payable.
Section Five
Surplus Received or Accrued by Social and/or Religious Institutions and
Organizations Excluded from Income Tax Objects
Article 48

(1) The surplus received or accrued by social and/or religious institutions and
organizations listed in corresponding agencies, are excluded from Income Tax objects
provided that the surplus is used for the construction and/or procurement of social
and/or religious facilities and infrastructure of a minimum of 25% (twenty-five percent)
of the surplus.
(2) If there is residue from the use of surplus for the construction and/or procurement of
social and/or religious facilities and infrastructure referred to in paragraph (1), the
surplus is placed as endowment funds.
(3) The construction and/or procurement of facilities and infrastructure as well as the
allocation in the form of endowment funds referred to in paragraph (1) and paragraph
(2) are carried out within no more than a period of 4 (four) years since the surplus is
(4) The provisions on the use of surplus referred to in paragraph (3) are listed in Appendix
XI which constitutes an integral part of this Ministerial Regulation.
(5) Social institutions or organizations referred to in paragraph (1) are non-profit social
welfare institutions or organizations that constitute legal entities as stipulated under
statutory provisions in the field of social welfare and their main activities include
organizing:
a. free health care;
b. care for the elderly or nursing homes;
c. care for fatherless and/or motherless orphans, abandoned children or people

and children or people with disabilities;
d. compensation and/or aid for victims of natural disasters, accidents, poverty,

remoteness, social disabilities and behavioral deviations, acts of violence and the
like;
e. scholarships; and/or
f. environmental preservation.
(6) Religious institutions and organizations referred to in paragraph (1) are non-profit
organizations whose main activity is managing places of worship and/or organizing
religious activities.
(7) Corresponding agencies referred to in paragraph (1) are:

a. government agencies at the central, provincial or regency/municipal levels in
charge of social affairs for social institutions and organizations; and
b. government agencies at the central, provincial or regency/municipal in charge of

religious affairs for religious institutions and organizations.
(8) Surplus referred to in paragraph (1) is the surplus of the calculation of all income
received or accrued other than income subject to final Tax Income and/or non Income
Tax objects less the costs to obtain, collect and maintain such income.
(9) The costs to obtain, collect and maintain income referred to in paragraph (8) include:
a. aid, donations or grants;
b. operational costs for organizing social and/or religious activities; and/or
c. procurement costs of goods and/or services used to support social and/or

religious activities.
(10) Aid, donations or grants referred to in paragraph (9) subparagraph a may be deducted
from gross income pursuant to statutory tax provisions, insofar as there is no special
relationship as referred to in the Income Tax Law.
(11) Not included as special relationships in the form of ownership and control relationships
referred to in paragraph (10) if the donor and donee of aid, donations or grants are
social and/or religious institutions or organizations as referred to in paragraph (5) and
paragraph (6).
Article 49
(1) Social and/or religious facilities and infrastructure referred to in Article 48 paragraph (1)
include:
a. the procurement of social and/or religious facilities;
b. the construction and procurement of social and/or religious infrastructure,

including buildings, land, offices, houses of worship; and/or
c. the procurement of facilities and infrastructure for public facilities,
located within the territory of the Unitary State of the Republic of Indonesia.

(2) The surplus may be allocated in the form of endowment funds as referred to in Article
48 paragraph (2) provided that:
a. there are provisions pertaining to endowment funds in social and/or religious

institutions and organizations in the form of Presidential Regulations and/or
Ministerial Regulations in charge of social or religious affairs; and
b. approved by:
1. the head of social and/or religious institutions or organizations; and
2. government agency officials at the central, provincial or regency/municipal

levels in charge of social or religious affairs.
(3) The surplus in the form of development and/or procurement of facilities and
infrastructure referred to in paragraph (1) subparagraph a and subparagraph b may be
given to other social and/or religious institutions and organizations listed in
corresponding agencies insofar as the said facilities and infrastructure are within the
territory of the Unitary State of the Republic of Indonesia.
(4) The surplus referred to in paragraph (1) subparagraph c and paragraph (3) may not be
deducted from gross income for the social and/or religious institutions and
organizations providing such surplus.
(5) Social and/or religious facilities and infrastructure referred to in paragraph (1)
subparagraph a and subparagraph b with a useful life of more than 1 (one) year are
charged through depreciation or amortization as pursuant to statutory provisions in
the field of Income Tax.
Article 50
(1) Social and/or religious institutions and organizations must file the amount of surplus
used for the construction and/or procurement of facilities and infrastructure and/or
allocated in the form of endowment funds referred to in Article 48 paragraph (1) and
paragraph (2).
(2) The report on the amount of surplus referred to in paragraph (1) is submitted annually
to the Head of the Tax Office where the social and/or religious institutions and
organizations are registered as an attachment to the Annual Tax Return.

(3) The provisions on the filing of the amount of surplus referred to in paragraph (1) are
listed in Appendix XII which constitutes an integral part of this Ministerial Regulation.
(4) In addition to the report referred to in paragraph (1), social and/or religious institutions
and organizations should m notes on details of the use of surplus supplemented with
supporting evidence.
Article 51
(1) The surplus that is not used for the construction and/or procurement of facilities and
infrastructure or endowment funds within a period of 4 (four) years as referred to in
Article 48 paragraph (3) is recognized as an Income Tax object at the end of the Tax
Year after the period of 4 (four) years ends.
(2) The amount of surplus referred to in paragraph (1) must be filed as an additional
Income Tax object in the Annual Income Tax Return for the Tax Year in which the
surplus is recognized as a fiscal correction.
(3) The provisions on the calculation of the amount of surplus not used for the
construction and/or procurement of facilities and infrastructure or endowment funds
within the period of 4 (four) years as referred to in paragraph (1) are listed in Appendix
XIII which constitutes an integral part of this Ministerial Regulation.
Article 52
(1) Endowment funds referred to in Article 48 paragraph (2) may be developed based on
sound business practices and managed risks, taking into account the principles of
good governance and pursuant to statutory provisions.
(2) Yield from the development of endowment funds referred to in paragraph (1):
a. is subject to tax pursuant to statutory tax provisions; and
b. may be used for operational activities, specifically for the procurement of social
and/or religious facilities and infrastructure.

(3) In the event that the use of endowment funds sourced from the surplus referred to in
Article 49 paragraph (2) does not comply with the provisions of paragraph (1), the
endowment funds shall constitute an Income Tax object in the Tax Year they are found
and treated as a fiscal correction.
Article 53
In the event that the social and/or religious institutions or organizations are mainly engaged
in education and/or research and development, the surplus for the social and/or religious
institutions or organizations shall be treated in accordance with the Minister of Finance
Regulation concerning the Income Tax treatment on scholarships that fulfill certain
requirements and the surplus received or accrued by non-profit institutions and
organizations engaged in education and/or research and development.
CHAPTER III
VALUE ADDED TAX AND SALES TAX ON LUXURY GOODS
Section One
Criteria of Not Having Performed Supplies of Taxable Goods and/or
Taxable Services and/or Exports of Taxable Goods and/or Taxable
Services, Determination of Certain Business Sectors as well as
Procedures for the Refund of Input VAT
Article 54
(1) Taxable Persons for VAT Purposes that Have Not Performed Any Supply may credit
Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of
Taxable Goods as well as utilization of intangible Taxable Goods and/or utilization of
Taxable Services from outside the Customs Area within the Customs Area.
(2) Input VAT referred to in paragraph (1) shall be credited pursuant to the provisions on
Input VAT crediting regulated under statutory tax provisions.
(3) Taxable Persons for VAT Purposes that Have Not Performed Any Supply may apply for a
refund of Input VAT overpayment at the end of the accounting year.

Article 55
(1) Creditable Input VAT referred to in Article 54 paragraph (1) becomes non-creditable, if
within a certain period:
a. the Taxable Person for VAT Purposes Has Not Performed Any Supply; or
b. the Taxable Person for VAT Purposes Has Not Performed Any Supply dissolved
(terminated) the business or the Taxable Person for VAT Purposes is
deregistered based on an application or ex officio.
(2) The criteria for not having performed supplies referred to in paragraph (1) is a state in
which a Taxable Person for VAT Purposes whose main business is in the sector of:
a. trading, if within a certain period does not carry out the following activities:
1. supplies of Taxable Goods; and/or
2. exports of Taxable Goods;
b. services, if within a certain period does not carry out the following activities:
1. supplies of Taxable Services; and/or
2. exports of Taxable Services; or
c. producing Taxable Goods, if within a certain period does not carry out the
following activities:
1. supplies of self-produced Taxable Goods; and/or
2. exports of self-produced Taxable Goods.
(3) Included in the criteria of not having performed supplies referred to in paragraph (2) is
if within the certain period as referred to in paragraph (1) Taxable Person for VAT
Purposes solely carries out the following activities:
a. personal use and/or free-of-charge Taxable Goods and/or Taxable Services;
b. supplies from the head office to branches or vice versa and/or supplies between
branches;
c. supplies of Taxable Goods in the form of assets which, according to their original
purpose, are not for sale; and/or

d. supplies of Taxable Goods and/or Taxable Services that are not directly related to
the Taxable Person for VAT Purposes’ main business.
Article 56
(1) The certain period referred to in Article 55 paragraph (1) is a period of up to 3 (three)
years since the Taxable Period of the first Input VAT crediting.
(2) The certain period referred to in paragraph (1) for certain business sectors may be set
to more than 3 (three) years.
(3) The stipulation of certain period for certain business sectors referred to in paragraph
(2) is limited to:
a. business sectors producing Taxable Goods referred to in Article 55 paragraph (2)

subparagraph c, the period is set to 5 (five) years since the Taxable Period of the
first Input VAT crediting; or
b. business sectors included in the statutory provisions on the acceleration of

national strategic projects assigned by the government, the period is set for 6
(six) years since the Taxable Period of the first Input VAT crediting.
Article 57
(1) If Taxable Persons for VAT Purposes that Have Not Performed Any Supply change their
business in a certain period as referred to in Article 56 paragraph (1) or paragraph (3)
subparagraph a and the credited Input VAT on acquisitions of Taxable Goods and/or
Taxable Services, imports of Taxable Goods as well as utilization of intangible Taxable
Goods and/or utilization Taxable Services from outside the Customs Area within the
Customs Area is directly related to the new business, the credited input VAT for which
an application for refund has not been submitted is creditable.

(2) If Taxable Persons for VAT Purposes that Have Not Performed Any Supply change their
business in a certain period as referred to in Article 56 paragraph (1) or paragraph (3)
subparagraph a and the credited Input VAT on acquisitions of Taxable Goods and/or
Goods and/or utilization Taxable Services from outside the Customs Area within the
Customs Area is not directly related to the new business, the credited input VAT for
which an application for refund has not been submitted becomes non-creditable.
(3) Taxable Persons for VAT Purposes that Have Not Performed Any Supply that change
their business in a certain period as referred to in Article 56 paragraph (1) or paragraph
(3) subparagraph a must refund the Input VAT on acquisitions of Taxable Goods and/or
Goods and/or utilization of Taxable Services from outside the Customs Area within the
Customs Area if:
a. the Input VAT is not directly related to the new business; and
b. the Taxable Persons for VAT Purposes have received tax refunds of the Input VAT
and/or have credited the said Input VAT against the Output VAT payable in a
Taxable Period.
(4) Taxable Persons for VAT Purposes must rectify the Periodic VAT Return in the event
that Input VAT becomes non-creditable as referred to in paragraph (2).
Article 58
(1) Non-creditable Input VAT referred to in Article 55 paragraph (1), after the certain period
referred to in Article 56 paragraph (1) or paragraph (3) ends:
a. must be refunded to the state treasury by the Taxable Persons for VAT Purposes;
and/or
b. cannot be carried forward to the next Taxable Period and application for refunds
cannot be submitted.
(2) The obligation to refund non-creditable Input VAT referred to in paragraph (1)
subparagraph a is carried out in the event that the Taxable Persons for VAT Purposes
have received the tax refunds for the said Input VAT and/or have credited the said
Input VAT against Output VAT payable in a Taxable Period.

(3) Input VAT cannot be carried forward to the next Taxable Period and application for
refunds cannot be submitted referred to in paragraph (1) subparagraph b if the said tax
refunds have been carried forward and a refund has not been requested.
(4) Output VAT referred to in paragraph (2) includes Output VAT on the activities referred
to in Article 55 paragraph (3).
Article 59
(1) Refund of Input VAT referred to in Article 58 paragraph (2) amounts to Input VAT for
which tax refunds have been granted and/or have been credited against Output VAT
payable in a Taxable Period.
(2) Refund of Input VAT referred to in paragraph (1) becomes payable upon:
a. certain period referred to in Article 56 paragraph (1) or paragraph (3) ends;
b. the date of dissolution (termination) of the business or the deregistration of

Taxable Persons for VAT Purposes referred to in Article 55 paragraph (1)
subparagraph b; or
c. the Taxable Period in which the change in the business is carried out as referred
to in Article 57 paragraph (3).
(3) Refund of Input VAT referred to in paragraph (1), is carried out no later than:
a. the end of the month following the expiration date of certain period referred to in
Article 56 paragraph (1);
b. the end of the following month after the expiration date of the certain period for
certain business sectors referred to in Article 56 paragraph (3); or
c. the end of the following month after the date of dissolution (termination) of the
business or the deregistration of Taxable Persons for VAT Purposes referred to in
Article 55 paragraph (1) subparagraph b.
(4) In the event that Taxable Persons for VAT Purposes change their business as referred
to in Article 57 paragraph (3), Input VAT is refunded no later than the end of the
following month after the Taxable Period of the change in business.

(5) Refund of Input VAT referred to in paragraph (1) shall be performed using a Tax
Payment Slip or other administrative means equivalent to a Tax Payment Slip pursuant
to statutory provisions by including the information “Refund of Input VAT” in the
description column.
(6) Refund of Input VAT referred to in paragraph (5) uses account tax code 411219 for
other VAT and remittance type code 100 for payments of other VAT payable.
(7) Refund of Input VAT referred to in paragraph (5), cannot be credited as Input VAT.
(8) Refund of Input VAT referred to in paragraph (5), is filed in the Periodic VAT Return for
the Taxable Period payment is performed by the Taxable Persons for VAT Purposes.
(9) The provisions on the refund of Input VAT referred to in paragraph (1) and the filing in
the Periodic VAT Return referred to in paragraph (8) are listed in Appendix XIV which
constitutes an integral part of this Ministerial Regulation.
Article 60
(1) Director General of Taxes may audit Taxable Persons for VAT Purposes that Have Not
Performed Any Supply referred to in Article 55 paragraph (1) pursuant to statutory tax
provisions.
(2) For Taxable Persons for VAT Purposes that do not or under refund Input VAT in the
period referred to in Article 59 paragraph (3) or paragraph (4), Notice of Tax
Underpayment Assessment is issued pursuant to statutory tax provisions.
(3) Notice of Tax Underpayment Assessment referred to in paragraph (2) is issued for the
amount of Input VAT refund referred to in Article 59 paragraph (1) plus the
administrative penalties referred to in Article 13 paragraph (2a) of the General
Provisions and Tax Procedures Law.
(4) Taxable Persons for VAT Purposes that refund Input VAT after the due date of tax
payments referred to in Article 59 paragraph (3) or paragraph (4), are subject to
administrative penalties in the form of interest referred to in Article 9 paragraph (2a) of
the General Provisions and Tax Procedures Law.
(5) Refund of Input VAT listed in the Notice of Tax Underpayment Assessment referred to
in paragraph (3), is not included in creditable Input VAT referred to in Article 9
paragraph (9c) of the VAT Law.

(6) The Director General of Taxes deregisters Taxable Persons for VAT Purposes ex officio
for Taxable Persons for VAT Purposes that Have Not Performed Any Supply after
passing the certain period referred to in Article 56 paragraph (1) or paragraph (3).
Article 61
In the event that Taxable Persons for VAT Purposes Have Not Performed Any Supply as
referred to in Article 55 paragraph (1) subparagraph a due to force majeure with a national
disaster status declared by the competent authority/agency, the Taxable Persons for VAT
Purposes are not obliged to refund Input VAT referred to in Article 59 paragraph (1).
Section Two
Procedures for Input VAT Crediting
Article 62
(1) Input VAT in a Taxable Period is credited against Output VAT in the same Taxable
Period.
(2) For Taxable Persons for VAT Purposes that have performed supplies of Taxable Goods,
supplies of Taxable Services, exports of Taxable Goods, and/or exports of Taxable
Services but in a Taxable Period, there are no such supplies of and/or exports, the
input VAT in the said Taxable Period may be credited by the Taxable Persons for VAT
Purposes pursuant to statutory tax provisions.
(3) VAT listed in the Tax Invoice that fulfils the provisions under Article 13 paragraph (5)
and paragraph (9) of the VAT Law is Input VAT that may be credited by a Taxable
Person for VAT Purposes in a Taxable Period since the Entrepreneur is registered as a
Taxable Person for VAT Purposes pursuant to statutory tax provisions.
(4) VAT listed in certain documents equivalent to Tax Invoices that fulfil the provisions
under Article 13 paragraph (6) and paragraph (9) of the VAT Law is Input VAT that may
be credited by a Taxable Person for VAT Purposes in a Taxable Period since the
Entrepreneur is registered as a Taxable Person for VAT Purposes pursuant to statutory
tax provisions.

Article 63
(1) Creditable Input VAT referred to in Article 62 paragraph (1), but not yet credited against
Output VAT in the same Taxable Period, may be credited in the next Taxable Period no
later than 3 (three) Taxable Periods after the end of the Taxable Period in which the
Tax Invoice is prepared.
(2) Creditable Input VAT referred to in paragraph (1) must be Input VAT that has not been
expensed or has not been added (capitalized) in the acquisition price of Taxable
Goods or Taxable Services and complies with statutory tax provisions.
(3) Input VAT crediting in the next Taxable Period referred to in paragraph (1) shall be
carried out by Taxable Persons for VAT Purposes through the filing or rectification of
Periodic VAT Returns.
(4) The provisions on Input VAT crediting referred to in paragraph (1) are listed in Appendix
XV which constitutes an integral part of this Ministerial Regulation.
Article 64
(1) Tax Invoice prepared by stating the identity of the buyer of Taxable Goods or recipient
of Taxable Services in the form of the name, address and single identity number for
individual resident taxpayers pursuant to statutory provisions is a Tax Invoice that fulfils
the provisions under Article 13 paragraph (5) subparagraph b number 1 of the VAT
Law.
(2) VAT listed in the Tax Invoice referred to in paragraph (1) is Input VAT that may be
credited by a Taxable Person for VAT Purposes purchasing Taxable Goods or receiving
Taxable Services pursuant to statutory tax provisions.
XVI which constitutes an integral part of this Ministerial Regulation.
Article 65

(1) Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of
Taxable Goods as well as utilization of intangible Taxable Goods and/or utilization of
Taxable Services from outside the Customs Area within the Customs Area before an
Entrepreneur is registered as a Taxable Person for VAT Purposes, may be credited by
the Taxable Person for VAT Purposes.
(2) Provisions on Input VAT crediting referred to in paragraph (1) apply to the Taxable
Period before the Entrepreneur is registered as a Taxable Person for VAT Purposes,
namely the Taxable Period prior to the registration date of the Entrepreneur as a
Taxable Person for VAT Purposes as stated in the Taxable Person for VAT Purposes
registration letter.
(3) Input VAT referred to in paragraph (1) is credited against Output VAT that should be
collected by Taxable Persons for VAT Purposes on supplies of Taxable Goods and/or
Taxable Services since the Entrepreneur should be registered as a Taxable Person for
VAT Purposes pursuant to statutory tax provisions until the Entrepreneur is registered
as a Taxable Person for VAT Purposes.
(4) Input VAT referred to in paragraph (1) is calculated using the Input VAT crediting
guidelines of 80% (eighty percent) of the Output VAT that should be collected as
referred to in paragraph (3).
(5) Guidelines for Input VAT crediting referred to in paragraph (4) are applied to the
Taxable Period before the Entrepreneur is registered as a Taxable Person for VAT
Purposes, which is carried out through:
a. the filing of Periodic VAT Return; and/or
b. the stipulation of VAT liabilities through audits.
(6) VAT listed in the Tax Invoice and certain documents equivalent to a Tax Invoice for a
Taxable Period before the Entrepreneur is registered as a Taxable Person for VAT
Purposes, is non-creditable Input VAT.
(7) To use the Input VAT crediting guidelines referred to in paragraph (4), Taxable Persons
for VAT Purposes may not use:
a. other values as the Tax Base as referred to in Article 8A of the VAT Law to
calculate Output VAT that should be collected on supplies of Taxable Goods
and/or Taxable Services; and

b. guidelines for calculating Input VAT crediting for Taxable Persons for VAT
Purposes whose business turnover in 1 (one) year does not exceed a certain
amount as referred to in Article 9 paragraph (7) of the VAT Law or those who
conduct certain businesses as referred to in Article 9 paragraph (7a) of the VAT
Law to calculate the amount of creditable Input VAT.
(8) Periodic VAT Return referred to in paragraph (5) subparagraph a, is:
a. Periodic VAT Return, for Taxable Persons for VAT Purposes that do not use the
guidelines for calculating input VAT crediting referred to in Article 9 paragraph (7)
and paragraph (7a) of the VAT Law; or
b. Periodic VAT Returns for Taxable Persons for VAT Purposes that use guidelines
for calculating Input VAT crediting, for Taxable Persons for VAT Purposes that use
guidelines for calculating Input VAT crediting referred to in Article 9 paragraph (7)
and paragraph (7a) of the VAT Law.
(9) Periodic VAT Return referred to in paragraph (8) is filed by Taxable Persons for VAT
Purposes since the Entrepreneur should be registered as a Taxable Person for VAT
Purposes in:
a. the last Taxable Period in the accounting year before the accounting year in
which the Entrepreneur is registered as a Taxable Person for VAT Purposes,
which includes Output VAT on supplies of Taxable Goods and/or Taxable
Services for the accounting year period concerned; and/or
b. the last Taxable Period before the Entrepreneur registered as a Taxable Person
for VAT Purposes in the accounting year in which the Entrepreneur is registered
as a Taxable Person for VAT Purposes, which includes Output VAT on supplies of
Taxable Goods and/or Taxable Services before Entrepreneur registered as
Taxable Persons for VAT Purposes for the accounting year period concerned.
(10) The provisions on Input VAT crediting referred to in paragraph (3) and the filing of
Periodic VAT Returns referred to in paragraph (9) are listed in Appendix XVII which
Article 66

(1) An Entrepreneur that does not prepare Tax Invoices for supplies of Taxable Goods
and/or Taxable Services before the Entrepreneur is registered as a Taxable Person for
VAT Purposes does not fulfil the provisions stipulated under Article 14 paragraph (1)
subparagraph d of the General Provisions and Tax Procedures Law and is not subject
to administrative penalties stipulated under Article 14 paragraph (4) of the General
(2) Taxable Persons for VAT Purposes referred to in Article 65 paragraph (3), are subject to
administrative penalties in the form of:
a. fines as referred to in Article 7 paragraph (1) of the General Provisions and Tax
Procedures Law;
b. interest as referred to in Article 9 paragraph (2a) of the General Provisions and

Tax Procedures Law or Article 13 paragraph (2) of the General Provisions and Tax
Procedures Law; and/or
c. surcharges as referred to in Article 15 of the General Provisions and Tax

Procedures Law.
(3) The calculation of administrative penalties referred to in paragraph (2) subparagraph b

is as follows:
a. interest as referred to in Article 9 paragraph (2a) of the General Provisions and

Tax Procedures Law is calculated from the payment due date for the Taxable
Period referred to in Article 65 paragraph (9) until the payment date and is
imposed for a maximum of 24 (twenty-four) months and part of the month is
calculated as 1 (one) full month; or
b. interest referred to in Article 13 paragraph (2) of the General Provisions and Tax
Procedures Law is calculated from the end of the Taxable Period referred to in
Article 65 paragraph (9) until the issuance of a Notice of Tax Underpayment
Assessment and is imposed for a maximum of 24 (twenty-four) months and part
of the month is calculated as 1 (one) full month.
(4) Input VAT referred to in Article 65 paragraph (6) may not be expensed or added
(capitalized) in the acquisition price of the Taxable Goods or Taxable Services by
Taxable Persons for VAT Purposes crediting the Input VAT using the guidelines for
Input VAT crediting guidelines referred to in Article 65 paragraph (4).
(5) In the event that Input VAT referred to in paragraph (4) has been expensed or has
been added (capitalized) to the acquisition price of Taxable Goods or Taxable Services:

a. the Taxable Persons for VAT Purposes are required to rectify the Annual Tax
Return in the Tax Year when the Input VAT has been expenses or has been
added (capitalized) to the acquisition price of Taxable Goods or Taxable Services;
or
b. the Director General of Taxes based on the application of Taxable Persons for
VAT Purposes or ex officio rectifies the assessments or decisions pursuant to
the provisions under Article 16 of the General Provisions and Tax Procedures
Law.
Article 67
Taxable Goods and utilization of intangible Taxable Goods and/or utilization of Taxable
Services from outside the Customs Area within the Customs Area, which are not filed in
the Periodic VAT Return notified and/or discovered during an audit, may be credited by
Taxable Persons for VAT Purposes pursuant to statutory tax provisions.
(2) Input VAT that is not filed in the Periodic VAT Return notified and/or discovered at the
time of audit referred to in paragraph (1) is the VAT listed in:
a. the Tax Invoices; and/or
b. certain documents equivalent to Tax Invoices.
(3) Input VAT crediting referred to in paragraph (1) is carried out upon the audit to be
taken into account in tax assessments to be issued under the documents referred to
in paragraph (2) which:
a. are notified by Taxable Persons for VAT Purposes by showing and/or lending the
said documents pursuant to the provisions of the Minister of Finance Regulation
concerning procedures for audits; and/or
b. are discovered by the Director General of Taxes.
(4) Input VAT crediting referred to in paragraph (1) may be carried out insofar as the
notification of tax audit findings has not been submitted to Taxable Persons for VAT
Purposes.
XVIII which constitutes an integral part of this Ministerial Regulation.

Article 68
Services from outside the Customs Area within the Customs Area, which is collected
with the issuance of tax assessments, may be credited by Taxable Persons for VAT
Purposes in the amount of the principal amount stated in the tax assessment,
provided that:
a. the said tax assessment constitutes a notice of tax assessment issued only to
collect Input VAT on the acquisitions of Taxable Goods and/or Taxable Services,
imports of Taxable Goods and utilization of intangible Taxable Goods and/or
utilization of Taxable Services from outside the Customs Area within the Customs
Area;
b. the Taxable Persons for VAT Purposes approve all audit findings on the tax
assessment;
c. the amount of outstanding VAT includes the principal tax and penalties as stated
in the paid tax assessment;
d. no legal action has been taken on the tax assessment; and
e. pursuant to statutory tax provisions.
(2) The amount of outstanding VAT referred to in paragraph (1) subparagraph c shall be
settled by Taxable Persons for VAT Purposes using a Tax Payment Slip or other
administrative means equivalent to a Tax Payment Slip.
(3) Tax Payment Slip or other administrative means equivalent to a Tax Payment Slip
referred to in paragraph (2) are in the form of:
a. proof of state revenue as stipulated under the Minister of Finance Regulation

concerning the electronic state revenue system;
b. overbooking receipt that has been signed by the competent authority as

stipulated under the Minister of Finance Regulation concerning procedures for
the payment and remittance of taxes; and/or
c. Fund Disbursement Order or proof of state revenue as proof of compensation for

Tax Liability as stipulated under the Minister of Finance Regulation concerning
calculation procedures and tax refunds.

(4) No legal action has been taken on the tax assessment referred to in paragraph (1)
subparagraph d includes no application for the following is submitted:
a. objections as referred to in Article 25 of the General Provisions and Tax

Procedures Law;
b. appeals as referred to in Article 27 of the General Provisions and Tax Procedures

Law;
c. reduction or nullification of administrative penalties as referred to in Article 36

paragraph (1) subparagraph a of the General Provisions and Tax Procedures Law;
d. reduction or cancellation of the notice of tax assessment as referred to in Article

36 paragraph (1) subparagraph b of the General Provisions and Tax Procedures
Law;
e. cancellation of tax audit findings or tax assessments as referred to in Article 36

paragraph (1) subparagraph d of the General Provisions and Tax Procedures Law;
and/or
f. civil reviews as referred to in statutory provisions on tax court.
(5) Included in no legal action has been taken referred to in paragraph (4), is no lawsuit as
referred to in Article 23 of the General Provisions and Tax Procedures Law is filed.
(6) Tax assessments which are attached with all Tax Payment Slips or other administrative
means equivalent to Tax Payment Slips for the settlement of the amount of
outstanding VAT referred to in paragraph (3) constitute certain documents equivalent
to Tax Invoices.
(7) Input VAT crediting referred to in paragraph (1), is carried out by filing certain
documents equivalent to Tax Invoice referred to in paragraph (6) in the Periodic VAT
Return in the Taxable Period the tax assessment is settled or in the next Taxable
Period no later than 3 (three) Taxable Periods after the end of the Taxable Period the
tax assessment is settled.
(8) The provisions on Input VAT crediting referred to in paragraph (1) and filing in Periodic
VAT Returns referred to in paragraph (7) are listed in Appendix XIX which constitutes
an integral part of this Ministerial Regulation.

Section Three
Procedures for the Preparation of Tax Invoices and Procedures for the
Rectification or Replacement of Tax Invoices
Article 69
(1) Taxable Persons for VAT Purposes must prepare a Tax Invoice for each:
a. supply of Taxable Goods as referred to in Article 4 paragraph (1) subparagraph a

and/or Article 16D of the VAT Law;
b. supply of Taxable Services as referred to in Article 4 paragraph (1) subparagraph

c of the VAT Law;
c. export of tangible Taxable Goods as referred to in Article 4 paragraph (1)

subparagraph f of the VAT Law;
d. export of intangible Taxable Goods as referred to in Article 4 paragraph (1)

subparagraph g of the VAT Law; and/or
e. export of Taxable Services as referred to in Article 4 paragraph (1) subparagraph

h of the VAT Law.
(2) Tax Invoice referred to in paragraph (1) must be prepared upon:
a. a supply of Taxable Goods and/or Taxable Services;
b. receipt of payment if payment is received before the supply of Taxable Goods

and/or before the supply of Taxable Services;
c. receipt of term payment in the case of a supply of a part of work phases;
d. exports of tangible Taxable Goods, exports of intangible Taxable Goods, and/or

exports of Taxable Services; or
e. certain times regulated by statutory provisions in the field of VAT.
Article 70

(1) Excluded from the provisions referred to in Article 69 paragraph (1), Taxable Persons
for VAT Purposes may prepared 1 (one) Tax Invoice which includes all supplies to the
same buyer of Taxable Goods and/or recipient of Taxable Services for 1 (one) calendar
month.
(2) Tax Invoice referred to in paragraph (1) is referred to as a combined Tax Invoice.
(3) The combined Tax Invoice referred to in paragraph (2) must be prepared no later than
the end of the month of the supplies of Taxable Goods and/or Taxable Services.
Article 71
(1) Tax Invoices prepared by Taxable Persons for VAT Purposes after a period of 3 (three)
months from the time the Tax Invoice should be prepared as referred to in Article 69
paragraph (2) and Article 70 paragraph (3) are not treated as Tax Invoices.
(2) Taxable Persons for VAT Purposes preparing the Tax Invoices referred to in paragraph
(1) shall be deemed not to have prepared the Tax Invoices.
(3) Taxable Persons for VAT Purposes referred to in paragraph (2) are subject to penalties
pursuant to statutory tax provisions.
(4) VAT stated in the Tax Invoices referred to in paragraph (1) is non-creditable Input VAT.
Article 72
(1) A Tax Invoice must include information on supplies of Taxable Goods and/or Taxable
Services which at least contains:
a. the name, address and Taxpayer Identification Number of the supplier of Taxable
Goods or Taxable Services;
b. the identity of the buyer of Taxable Goods or recipient of Taxable Services which
includes:
1. name, address and Taxpayer Identification Number, for resident taxpayers

and government agencies;

2. name, address and Taxpayer Identification Number or single identity
number, for individual resident taxpayers pursuant to statutory provisions;
3. name, address and passport number, for non-resident individual taxpayers;

or
4. name and address, for non-resident corporate taxpayers or non-taxpayers

as referred to in Article 3 of the Income Tax Law;
c. the types of goods or Services, total selling price or considerations and

discounts;
d. collected VAT;
e. collected Sales Tax on Luxury Goods;
f. code, serial number and preparation date of the Tax Invoice; and
g. the name and signature of the person entitled to sign the Tax Invoice.
(2) Single identity number referred to in paragraph (1) subparagraph b number 2 is

equivalent to the Taxpayer Identification Number in the context of preparing Tax
Invoices and Input VAT crediting.
Article 73
(1) Tax Invoices referred to in Article 72 paragraph (1):
a. are in the electronic format;
b. are preparing using the application or system provided and/or stipulated by the
Directorate General of Taxes; and
c. includes a signature in the form of an Electronic Signature.
(2) Excluded from the provisions referred to in paragraph (1), Tax Invoices for:
a. supplies of Taxable Goods to individual foreign passport holders referred to in

Article 16E of the VAT Law, prepared pursuant to statutory tax provisions on
procedures for the application and settlement of requests for the return of
personal effects for foreign passport holders;

b. supplies of Taxable Goods and/or Taxable Services to buyers of Taxable Goods
and/or recipients of Taxable Services with the end consumer characteristics,
prepared pursuant to the provisions under Article 13 paragraph (5a) of the VAT
Law; and
c. supplies of Taxable Goods, supplies of Taxable Services, exports of Taxable

Goods, exports of intangible Taxable Goods and/or exports of Taxable Services,
in which the proof of VAT collection is in the form of certain documents
equivalent to Tax Invoices, prepared pursuant to the provisions under Article 13
paragraph (6) of the VAT Law.
Article 74
(1) Tax Invoices referred to in Article 73 paragraph (1) must:
a. be uploaded by Taxable Persons for VAT Purposes using the application or

system provided and/or stipulated by the Directorate General of Taxes; and
b. obtain approval from the Directorate General of Taxes.
(2) Tax Invoices in the electronic format that do not obtain approval from the Directorate
General of Taxes referred to in paragraph (1) subparagraph b do not constitute Tax
Invoices.
(3) VAT listed in the Tax Invoices referred to in paragraph (2) is non-creditable Input VAT.
Article 75
Sales invoices issued by Taxable Persons for VAT Purposes are included in the definition of
Tax Invoices referred to in Article 73 paragraph (1) insofar as:
1. including information referred to in Article 72 paragraph (1);
2. uploaded using the application or system provided and/or stipulated by the Directorate
General of Taxes; and
3. obtaining approval from the Directorate General of Taxes.

Article 76
(1) Taxable Persons for VAT Purposes may prepare a replacement Tax Invoice for the Tax
Invoice referred to in Article 73 paragraph (1) if there is an error in the completion or
typo in the Tax Invoice, thereby, it does not contain correct, complete and clear
information.
(2) Taxable Persons for VAT Purposes may reprint the Tax Invoice if the printed Tax Invoice
referred to in Article 73 paragraph (1) is damaged or lost.
(3) Taxable Persons for VAT Purposes may request Tax Invoice data in the electronic
format from the Directorate General of Taxes if the Tax Invoice data referred to in Article
73 paragraph (1) is damaged or lost.
(4) Taxable Persons for VAT Purposes must cancel the Tax Invoice that has been
prepared for supplies of:
a. Taxable Goods and/or Taxable Services of which the transactions are canceled;
or
b. goods and/or services for which a Tax Invoice should not be prepared.
Article 77
(1) In the event of certain circumstances that cause Taxable Persons for VAT Purposes to
be unable to prepare a Tax Invoice in the electronic format as referred to in Article 73
paragraph (1), Taxable Persons for VAT Purposes are permitted to prepare a Tax
Invoice in a non-electronic format.
(2) Certain circumstances referred to in paragraph (1) are circumstances caused by wars,
riots, revolutions, natural disasters, strikes, fires and other causes beyond the control
of the Taxable Persons for VAT Purposes, as stipulated by the Director General of
Taxes.
Article 78
(1) Tax Invoices must be filled out correctly, completely and clearly.

(2) Taxable Persons for VAT Purposes that prepare a Tax Invoice that does not comply
with the provisions of paragraph (1) are subject to penalties pursuant to statutory tax
provisions.
(3) VAT listed in the Tax Invoice referred to in paragraph (2) is non-creditable Input VAT.
Section Four
Tax Invoices for Retailer Taxable Persons for VAT Purposes Supplying
Taxable Goods and/or Taxable Services to Buyers with End Consumer
Characteristics
Article 79
(1) Supplies of Taxable Goods and/or Taxable Services to buyers of Taxable Goods and/or
recipients of Taxable Services with the end consumer characteristics are retail
supplies.
(2) End consumer characteristics referred to in paragraph (1) include:
a. buyers of goods and/or recipients of services that directly consume purchased

or received goods and/or services; and
b. buyers of goods and/or recipients of services that do not use or utilize

purchased or received goods and/or services for business.
(3) Taxable Persons for VAT Purposes whose entire or part of their business is supplying
Taxable Goods and/or Taxable Services to buyers of Taxable Goods and/or recipients
of Taxable Services with the end consumer characteristics as referred to in paragraph
(2), including those performed through Electronic Commerce, constitute retailer
Taxable Persons for VAT Purposes.
Article 80

(1) Retailer Taxable Persons for VAT Purposes referred to in Article 79 paragraph (3) may
prepare a Tax Invoice for each of Taxable Goods and/or Taxable Services without
specifying the buyer’s identity as referred to in Article 72 paragraph (1) subparagraph b
and the seller’s name and signature as referred to in Article 72 paragraph (1)
subparagraph g.
(2) Tax Invoices referred to in paragraph (1) for supplies of Taxable Goods and/or Taxable
Services to buyers of Taxable Goods and/or recipients of Taxable Services with the end
consumer characteristics referred to in Article 79 paragraph (2) must be prepared by
including information which at least contains:
a. name, address and Taxpayer Identification Number of the supplier of Taxable

Goods and/or Taxable Services;
b. the types of goods or services, total selling price or considerations and

discounts;
c. collected VAT or VAT and Sales Tax on Luxury Goods; and
d. code, serial number and preparation date of the Tax Invoice.
(3) Tax Invoices referred to in paragraph (2) may be in the form of cash receipts, sales
invoices, cash register receipts, tickets, receipts or proof of supplies of or other similar
payments.
(4) VAT or VAT and Sales Tax on Luxury Goods referred to in paragraph (2) subparagraph c
may be included in the selling price or considerations or listed separately.
(5) The code and the serial number of the Tax Invoices referred to in paragraph (2)
subparagraph d may be self-determined according to the common business practice
of the retailer Taxable Persons for VAT Purposes.
(6) Tax Invoices referred to in paragraph (2) shall be prepared at least for:
a. buyers of Taxable Goods and/or recipients of Taxable Services; and
b. the archive of retailer Taxable Persons for VAT Purposes.
(7) Archive of retailer Taxable Persons for VAT Purposes referred to in paragraph (6)
subparagraph b may be in the form of Tax Invoice records in the form of electronic
media as a means of data storage.
(8) Taxable Persons for VAT Purposes may prepare Tax Invoices referred to in paragraph
(2) for:

a. personal use of Taxable Goods and/or Taxable Services that are not related to
subsequent production activities or are used for activities that are not directly
related to the said Taxable Persons for VAT Purposes’ business; and
b. free-of-charge provision of Taxable Goods and/or Taxable Services to buyers of

Taxable Goods and/or recipients of Taxable Services with the end consumer
characteristics as referred to in Article 79 paragraph (2).
(9) Retailer Taxable Persons for VAT Purposes may prepare the Tax Invoices referred to in
paragraph (2) for supplies of Taxable Goods and/or Taxable Services eligible for the
VAT non-collected or VAT exempt facilities.
(10) VAT listed in the Tax Invoices referred to in paragraph (2) is non-creditable Input VAT.
Article 81
(1) Excluded from the provisions referred to in Article 80 paragraph (2), Tax Invoices for
supplies of certain Taxable Goods and/or certain Taxable Services to buyers of the
Taxable Goods and/or recipients of Taxable Services with the end consumer
characteristics referred to in Article 79 paragraph (2) are prepared pursuant to the
provisions of Article 73 paragraph (1).
(2) Certain Taxable Goods referred to in paragraph (1) include:
a. land transportation in the form of motor vehicles;
b. water transportation in the form of cruise ships, excursion boats, ferries and/or
yachts;
c. air transportation in the form of airplanes, helicopters and/or hot air balloons;
d. land and/or buildings; and
e. firearms and/or bullets.
(3) Certain Taxable Services referred to in paragraph (1) include:
a. land transportation rental services in the form of motor vehicles;
b. water transportation rental services in the form of cruise ships, excursion boats,
ferries and/or yachts;

c. air transportation rental services in the form of airplanes, helicopters and/or hot
air balloons; and
d. land and/or building rental services.
Article 82
(1) Tax Invoices referred to in Article 80 paragraph (2) must be filled out correctly,
completely and clearly.
(2) Retailer Taxable Persons for VAT Purposes that prepare Tax Invoices that do not
comply with the provisions of paragraph (1) are subject to penalties pursuant to
statutory tax provisions.
CHAPTER IV
GENERAL PROVISIONS AND TAX PROCEDURES
Section One
Procedures for Interest Compensation
Article 83
(1) Interest compensation related to Income Tax, VAT and Sales Tax on Luxury Goods are
granted to Taxpayers in the event of:
a. a delay in tax refunds as referred to in Article 11 paragraph (3) of the General

Provisions and Tax Procedures Law;
b. a delay in the issuance of the Notice of Tax Overpayment Assessment as referred

to in Article 17B paragraph (3) of the General Provisions and Tax Procedures Law;
c. a delay in the issuance of the Notice of Tax Overpayment Assessment as referred

to in Article 17B paragraph (4) of the General Provisions and Tax Procedures Law;
d. tax overpayment due to a filed objection, appeal or civil review that is granted in
part or in whole as referred to in Article 27B paragraph (1) of the General
Provisions and Tax Procedures Law; or

e. tax overpayment due to the Notice of Tax Correction, decision letter on the
reduction or cancellation of the notice of tax assessment or decision letter on
the reduction or cancellation of the Notice of Tax Collection that grants part or all
of the Taxpayer’s application as referred to in Article 27B paragraph (3) of the
General Provisions and Tax Procedures Law, except for:
1. tax overpayment due to the Notice of Tax Correction in respect of Mutual

Agreement; or
2. tax overpayment due to the decision letter on the cancellation of the notice
of tax assessment as referred to in Article 36 paragraph (1) subparagraph d
of the General Provisions and Tax Procedures Law.
(2) Interest compensation referred to in paragraph (1) subparagraph d shall be granted for
the tax overpayment amounting to a maximum of the overpayment amount approved
by the Taxpayer in the Closing Conference for the Tax Return stating the overpayment
for which the following has been issued:
a. Notice of Tax Underpayment Assessment;
b. Notice of Additional Tax Underpayment Assessment;
c. Notice of Tax Overpayment Assessment; or
d. Notice of Nil Tax Assessment.
(3) The overpayment amount approved by the Taxpayer in the Closing Conference
referred to in paragraph (2) is the overpayment amount according to the Taxpayer
submitted by the Taxpayer in the Closing Conference.
(4) Tax Return stating an overpayment referred to in paragraph (2) is a Tax Return stating
an overpayment with an application for tax refunds.
(5) Interest compensation referred to in paragraph (1) subparagraph d shall not be

granted to tax overpayment due to the issuance of an Objection Decision Letter,
Appeal Decision or Civil Review Decision, which originates from payment of a Notice of
Tax Underpayment Assessment or Notice of Additional Tax Underpayment
Assessment, either approved or not approved by the Taxpayer in the Closing
Conference.
Article 84

(1) In the event of a delay in the refund of Land and Building Tax for the plantation sector,
forestry sector, mining sector and other sectors, interest compensation in respect of
Land and Building Tax shall be granted to the Taxpayer.
(2) The delay in the refund of Land and Building Tax referred to in paragraph (1), is the
result of the issuance of:
a. Decision Letter on the Land and Building Tax Overpayment;
b. Objection Decision;
c. Appeal Decision or Civil Review Decision;
d. Notice of Tax Correction;
e. Decision Letter on the Reduction of Land and Building Tax Administrative

Penalties or Decision Letter on the Nullification of Land and Building Tax
Administrative Penalties;
f. Decision Letter on the Reduction of Notice of Tax Due or Decision Letter on the
Cancellation of Notice of Tax Due;
g. Decision Letter on the Reduction of Notice of Land and Building Tax Assessment
or Decision Letter on the Cancellation of Land and Building Tax Assessment; or
h. Decision Letter on the Reduction of Notice of Land and Building Tax Collection or
Decision Letter on the Cancellation of Notice of Land and Building Tax Collection.
Article 85
(1) Interest compensation due to the delay in tax refunds referred to in Article 83
paragraph (1) subparagraph a is granted at a monthly interest rate stipulated by the
Minister of Finance, of the amount of tax overpayment.
(2) The number of months as the basis for the granting of interest compensation referred
to in paragraph (1) is calculated from the expiration of the issuance deadline of the
Preliminary Refunds Decision Letter or Calculation of Interest Compensation Decision
Letter until the issuance date of the Preliminary Refunds Decision Letter or Calculation
of Interest Compensation Decision Letter.

(3) The issuance deadline of the Preliminary Refunds Decision Letter or Calculation of
Interest Compensation Decision Letter referred to in paragraph (2) is no later than 1
(one) month since:
a. the application for tax refunds is received in connection with the issuance of the
Notice of Tax Overpayment Assessment referred to in Article 17 paragraph (1) of
the General Provisions and Tax Procedures Law;
b. the issuance of the Notice of Tax Overpayment Assessment referred to in Article

17 paragraph (2) or Article 17B of the General Provisions and Tax Procedures
Law;
c. the issuance of the Preliminary Tax Refunds Decision Letter for Taxpayers with
certain criteria referred to in Article 17C of the General Provisions and Tax
Procedures Law, Taxpayers that fulfil certain requirements referred to in Article
17D of the General Provisions and Tax Procedures Law and low-risk Taxable
Persons for VAT Purposes referred to in Article 9 paragraph (4c) of the VAT Law;
d. the issuance of the Objection Decision Letter, Notice of Tax Correction, Decision
Letter on the Reduction of Administrative Penalties, Decision Letter on the
Nullification of Administrative Penalties, decision letter on the reduction or
cancellation of the notice of tax assessment, decision letter on the reduction or
cancellation of the Notice of Tax Collection or Interest Compensation Decision
Letter, which results in a tax overpayment; or
e. the Appeal Decision or Civil Review Decision is received by the office of the
Directorate General of Taxes authorized to implement the Court’s Decision,
which results in a tax overpayment.
(4) Interest compensation referred to in paragraph (1) is granted for a maximum of 24

(twenty-four) months and part of the month is calculated as 1 (one) full month.
(5) The monthly interest rate referred to in paragraph (1) is the interest rate in effect on
the date the calculation of interest compensation commences.
Article 86
(1) Interest compensation due to the delay in the issuance of Notice of Tax Overpayment
Assessment referred to in Article 83 paragraph (1) subparagraph b is granted at the
monthly interest rate stipulated by the Minister of Finance, of the amount of tax
overpayment.
to in paragraph (1) is calculated from the expiration of the 1 (one) month period for the
issuance of a Notice of Tax Overpayment Assessment that complies with the
provisions under Article 17B paragraph (2) of the General Provisions and Tax
Procedures Law until the issuance of the Notice of Tax Overpayment Assessment.

Article 87
(1) Interest compensation due to the delay in the issuance of Notice of Tax Overpayment
Assessment referred to in Article 83 paragraph (1) subparagraph c is granted at the
monthly interest rate stipulated by the Minister of Finance, of the amount of tax
overpayment.
to in paragraph (1) is calculated from the expiration of the period of 12 (twelve) months
from the date on which the application letter for tax refunds is received in full until the
issuance of the Notice of Tax Overpayment Assessment.

Article 88
(1) Interest compensation for tax overpayment due to the filing of an objection, appeal or
application for a civil review related to the Tax Return stating overpayment referred to in
Article 83 paragraph (1) subparagraph d is granted at the monthly interest rate
stipulated by the Minister of Finance, of the amount of tax overpayment.

to in paragraph (1) is calculated from the issuance date of the Notice of Tax
Underpayment Assessment, Notice of Additional Tax Underpayment Assessment,
Notice of Tax Overpayment Assessment or Notice of Nil Tax Assessment until the
issuance of Objection Decision Letter or the pronouncement of Appeal Decision or Civil
Review Decision.

Article 89
(1) Interest compensation on tax overpayment due to Notice of Tax Correction, decision
letter on the reduction or cancellation of the notice of tax assessment or decision
letter on the reduction or cancellation of the Notice of Tax Collection, referred to in
Article 83 paragraph (1) subparagraph e is granted at the monthly interest rate
stipulated by the Minister of Finance, of the amount of tax overpayment.
to in paragraph (1) is calculated from:
a. the payment date of the Notice of Tax Underpayment Assessment or the Notice
of Additional Tax Underpayment Assessment until the issuance date of the
Notice of Tax Correction or decision letter on the reduction or cancellation of the
notice of tax assessment; or
b. the issuance date of the Notice of Tax Overpayment Assessment or Notice of Nil
Tax Assessment until the issuance date of the Notice of Tax Correction or
decision letter on the reduction or cancellation of the notice of tax assessment;
or
c. the payment date of the Notice of Tax Collection until the issuance date of the
Notice of Tax Correction or decision letter on the reduction or cancellation of the
Notice of Tax Collection.


Article 90
(1) Interest compensation due to the delay in the refund of Land and Building Tax referred
to in Article 84 is granted at the monthly interest rate stipulated by the Minister of
Finance, of the amount of tax overpayment.
to in paragraph (1) is calculated from the expiration of the issuance deadline of the
Land and Building Tax Preliminary Refunds Decision Letter ends the issuance date of
the Land and Building Tax Preliminary Refunds Decision Letter.
(3) The issuance deadline of the Land and Building Tax Preliminary Refunds Decision
Letter referred to in paragraph (2) is no later than 1 (one) month since:
a. the issuance of the Land and Building Tax Overpayment Decision Letter;
b. the issuance of the Objection Decision;
c. the receipt of the Appeal Decision or Civil Review Decision by the office of the
Directorate General of Taxes authorized to implement the Appeal Decision or
Civil Review Decision;
d. the issuance of the Notice of Tax Correction;
e. the issuance of the Decision Letter on the Reduction of Land and Building Tax
Administrative Penalties or Decision Letter on the Nullification of Land and
Building Tax Administrative Penalties;
f. the issuance of the Decision Letter on the Reduction of Notice of Tax Due or
Decision Letter on the Cancellation of Notice of Tax Due;
g. the issuance of the Decision Letter on the Reduction of Notice of Land and
Building Tax Assessment or Decision Letter on the Cancellation of Land and
Building Tax Assessment; or
h. the issuance of the Decision Letter on the Reduction of Notice of Land and
Building Tax Collection or the Decision Letter on the Cancellation of Notice of
Land and Building Tax Collection.

Article 91
(1) In the event that there is interest compensation as referred to in Article 83, the
Taxpayer shall apply for the granting of interest compensation to the Head of the Tax
Office where the Taxpayer is registered or where the Taxable Person for VAT Purposes
is registered.
(2) In the event that there is interest compensation as referred to in Article 84, the
Taxpayer shall apply for the granting of interest compensation to the Head of the Tax
Office where the Land and Building Tax object is administered.
(3) The application referred to in paragraph (1) or paragraph (2) is submitted:
a. electronically, through certain channels stipulated by the Director General of

Taxes; or
b. in writing,
by including the Taxpayer’s domestic account number.
(4) Application in writing referred to in paragraph (3) subparagraph b is submitted:
a. directly;
b. by post with proof of mail delivery; or
c. through a forwarder or courier service company with proof of postage.
Article 92
(1) Director General of Taxes issues an Interest Compensation Decision Letter if the
application for interest compensation referred to in Article 91 paragraph (1) or Article
91 paragraph (2):
a. fulfils the provisions under Article 83 or Article 84; and

b. includes the Taxpayer’s domestic account number referred to in Article 91
paragraph (3).
(2) Interest Compensation Decision Letter referred to in paragraph (1) in respect of the
granting of interest compensation on tax overpayment due to the filing of an objection,
appeal or civil review referred to in Article 83 paragraph (1) subparagraph d, may be
issued if:
a. for the Objection Decision Letter, an appeal is not filed to the Tax Court;
b. the Appeal Decision has been received by the office of the Directorate General of
Taxes authorized to grant interest compensation; or
c. the Civil Review Decision has been received by the office of the Directorate
General of Taxes which is authorized to grant interest compensation.
(3) In the event that the Interest Compensation Decision Letter is not issued because the
application for interest compensation referred to in Article 91 paragraph (1) or Article
91 paragraph (2) does not fulfil the provisions referred to in paragraph (1) and
paragraph (2), the Director General of Taxes issues a notification that the Interest
Compensation Decision Letter is not issued to the Taxpayer.
(4) Interest Compensation Decision Letter referred to in paragraph (1) or the notification
that the Interest Compensation Decision Letter is not issued referred to in paragraph
(3) is issued no later than 1 (one) month after the application for interest
compensation is received in full by the Tax Office.
(5) The provisions on the format of the Interest Compensation Decision Letter referred to
in paragraph (1) are listed in Appendix XX which constitutes an integral part of this
(6) The provisions on the format of the notification that the Interest Compensation
Decision Letter is not issued referred to in paragraph (3) are listed in Appendix XXI
(7) Interest Compensation Decision Letter referred to in paragraph (1) is issued based on
the tax calculation memo of interest compensation, which contains the calculation of
the amount of interest compensation granted to the Taxpayer.
(8) The provisions on the format of the tax calculation memo of interest compensation
referred to in paragraph
(7) are listed in Appendix XXII which constitutes an integral part of this Ministerial
Regulation.

(9) For Taxpayers that have obtained a permit to maintain bookkeeping in English and
United States Dollars, interest compensation in respect of tax payable in United States
Dollars are granted in Rupiah, which is calculated using the exchange rate stipulated
by the Minister of Finance in effect upon:
a. the issuance of the Notice of Tax Overpayment Assessment as referred to in

Article 17B of the General Provisions and Tax Procedures Law;
b. the issuance of the Objection Decision Letter or pronouncement of the Appeal

Decision or Civil Review Decision;
c. the issuance of the Notice of Tax Correction;
d. the issuance of the decision letter on the reduction or cancellation of the notice
of tax assessment; or
e. the issuance of the decision letter on the reduction or cancellation of the Notice
of Tax Collection.
Article 93
(1) The granting of interest compensation to a Taxpayer must be set off in advance

against the Tax Liability administered at the Tax Office where the Taxpayer is registered
and/or where the Taxable Person for VAT Purposes is registered, including at the Tax
Office where the branch Taxpayer is registered and the Tax Office where Land and
Building Tax objects are administered.
(2) Tax Liability referred to in paragraph (1) includes:
a. for a Taxable Period, a Fraction of a Tax Year or the 2007 Tax Year and earlier are
the Tax Liability of Income Tax, VAT and Sales Tax on Luxury Goods listed in:
1. the Notice of Tax Collection;
2. the Notice of Tax Underpayment Assessment or Notice of Additional Tax

Underpayment Assessment;
3. the Notice of Tax Correction, Objection Decision Letter, Appeal Decision as

well as Civil Review Decision, resulting in an increase in the amount of tax
payable; and/or

well as Civil Review Decision, resulting in tax refunds that should not
otherwise be refunded;
b. for a Taxable Period, a Fraction of a Tax Year or the 2008 Tax Year onwards is Tax
Liability of Income Tax, VAT and Sales Tax on Luxury Goods listed in:
1. the Notice of Tax Collection;

Underpayment Assessment for the amount approved by the Taxpayer in
the Closing Conference;

Underpayment Assessment for the amount not approved by the Taxpayer
Closing Conference, for which:
a) no objection is filed;
b) an objection is filed but the Objection Decision Letter partially grants,

rejects or increases the amount of tax payable and for the Objection
Decision Letter, no appeal is filed; or
c) an appeal is filed and for the Objection Decision Letter, an appeal is

filed but the Appeal Decision partially grants, increases the amount of
tax payable or rejects;
4. the Objection Decision Letter for which no objection is filed;
5. the Notice of Tax Correction resulting in an increase in the amount of tax

payable;
6. the Appeal Decision or Civil Review Decision, resulting in an increase in the

amount of tax payable; and/or

well as Civil Review Decision, resulting in tax refunds that should not
otherwise be refunded;
c. Tax Liability of Land and Building Tax listed in:
1. the Notice of Land and Building Tax Collection;
2. the Notice of Tax Due;
3. the Notice of Land and Building Tax Assessment;

4. the Objection Decision, Appeal Decision or Civil Review Decision, resulting
in an increase in the amount of tax payable;
5. the Notice of Tax Correction resulting in an increase in the amount of tax

payable; and/or
6. the Notice of Tax Correction, Objection Decision, Appeal Decision as well as

Civil Review Decision, resulting in tax refunds that should not otherwise be
refunded.
(3) In the event that after the calculation referred to in paragraph (1) is carried out, there is
residual interest compensation that must be paid to the Taxpayer, based on the
Taxpayer’s application, the residual interest compensation may be set off against:
a. tax that will be payable on behalf of the Taxpayer; and/or
b. Tax Liability and/or tax that will be payable on behalf of another Taxpayer.
Article 94
(1) Calculation of interest compensation against the Tax Liability and/or tax that will be
payable referred to in Article 93 is stated in the tax calculation memo of interest
compensation.
(2) The provisions on the format of the tax calculation memo of interest compensation
referred to in paragraph (1) are listed in Appendix XXIII which constitutes an integral
part of this Ministerial Regulation.
(3) Calculation of Interest Compensation Decision Letter is issued based on the tax
calculation memo of interest compensation referred to in paragraph (1).
(4) The provisions on the format of the Calculation of Interest Compensation Decision
Letter referred to in paragraph (3) are listed in Appendix XXIV which constitutes an
(5) Settlement of Tax Liability and/or tax that will be payable through the calculation of the
residual interest compensation referred to in Article 93 is recognized upon the
issuance of the Calculation of Interest Compensation Decision Letter.

Article 95
(1) The calculation of interest compensation against Tax Liability and/or tax that will be
payable referred to in Article 93 is followed up with the set-off against the Tax Liability
and/or tax that will be payable.
(2) In the event that there is no Tax Liability and/or tax that will be payable, all interest
compensation is granted to the Taxpayer concerned.
(3) The set-off against the Tax Liability and/or tax that will be payable referred to in
paragraph (1) shall be carried out through Interest Compensation Payment
withholding.
(4) Interest Compensation Payment withholding referred to in paragraph (3) is considered

valid if a State Revenue Transaction Number or a revenue reference number has been
obtained pursuant to statutory provisions in the field of treasury.
Article 96
(1) Based on the Calculation of Interest Compensation Decision Letter referred to in Article
94 paragraph (3), the Head of the Tax Office on behalf of the Minister of Finance issues
an Interest Compensation Payment Order.
(2) In the event of an error in the issuance of the Interest Compensation Payment Order
referred to in paragraph (1), the Head of the Tax Office on behalf of the Minister of
Finance rectifies the Interest Compensation Payment Order insofar as the Fund
Disbursement Order has not been issued.
(3) The provisions on the format of the Interest Compensation Payment Order referred to
in paragraph (1) are listed in Appendix XXV which constitutes an integral part of this
(4) Interest Compensation Payment Order referred to in paragraph (1) is prepared in 4

(four) copies, with the following designation:
a. copy 1 and copy 2 for the State Treasury Office;
b. copy 3 for the Taxpayer; and
c. copy 4 for the archive of the Tax Office.

(5) The Calculation of Interest Compensation Decision Letter and the Interest
Compensation Payment Order as well as Computer Data Archives are submitted to the
State Treasury Office.
Article 97
(1) Based on the Interest Compensation Payment Order referred to in Article 96 paragraph
(1), the Head of the State Treasury Office on behalf of the Minister of Finance issues a
Fund Disbursement Order provided that:
a. in the event that all interest compensation is set off against the Tax Liability
and/or tax that will be payable through Interest Compensation Payment
withholding, the Head of the State Treasury Office issues a Nil Fund
Disbursement Order;
b. in the event that there is residual interest compensation that must be given to
the Taxpayer after being set off against the Tax Liability and/or tax that will be
payable through Interest Compensation Payment withholding, the Head of the
State Treasury Office issues a Fund Disbursement Order according to the
Taxpayer’s account listed in the Interest Compensation Payment Order; or
c. in the event that all interest compensation is granted to the Taxpayer, the Head
of the State Treasury Office issues a Fund Disbursement Order according to the
Taxpayer’s account stated in the Interest Compensation Payment Order.
(2) Head of the State Treasury Office issues state revenue receipts in the event that
interest compensation is set off against the Tax Liability and/or tax that will be payable
through Interest Compensation Payment withholding.
(3) State Treasury Office submits:
a. Fund Disbursement Order list;
b. copy 2 of the Interest Compensation Payment Order; and
c. state revenue receipts, in the event there is interest compensation set off

against the Tax Liability and/or tax that will be payable through Interest
Compensation Payment withholding,
to the Tax Office issuing the Interest Compensation Payment Order.

Article 98
State revenue receipt for Interest Compensation Payment withholding shall be submitted by
the Tax Office issuing the Interest Compensation Payment Order to the Taxpayer.
Article 99
(1) Calculation of Interest Compensation Decision Letter referred to in Article 94 paragraph

(3) and the Interest Compensation Payment Order referred to in Article 96 paragraph
(1) is issued no later than 1 (one) month after the issuance of the Interest
Compensation Decision Letter.
(2) Fund Disbursement Order referred to in Article 97 paragraph (1) is issued by the Head
of the State Treasury Office pursuant to statutory provisions in the field of treasury.
Article 100
(1) The official authorized to sign the Calculation of Interest Compensation Decision Letter
and Interest Compensation Payment Order submits a signature specimen to the Head
of the State Treasury Office at the beginning of each fiscal year.
(2) In the event of a change in the official authorized to sign the Calculation of Interest
Compensation Decision Letter and Interest Compensation Payment Order, the
substitute official must submit a signature specimen to the Head of the State Treasury
Office from the time the person concerned takes office.
Article 101
Payment of interest compensation is part of tax revenue deductibles.

Article 102
Director General of Taxes issues the Notice of Tax Collection referred to in Article 14
paragraph (1) subparagraph h of the General Provisions and Tax Procedures Law to collect
interest compensation that should not otherwise be granted to a Taxpayer in the event that
a decision is issued, a decision is received or data or information is found, indicating the
existence of interest compensation that should not be otherwise be granted to the
Taxpayer.
Section Two
Procedures for the Payment and Remittance of Taxes
Article 103
Several provisions in the Minister of Finance Regulation Number 242/PMK.03/2014

concerning Procedures for the Payment and Remittance of Taxes (Official Gazette of the
Republic of Indonesia of 2014 Number 1973), are amended as follows:
1. The provisions of number 1, number 2, number 3, number 4, number 15, number 16,
number 17, number 21, number 22, number 23 and number 25 of Article 1 are
amended, thereby, Article 1 reads as follows:
Article 1
Referred to herein this Minister of Finance Regulation:
1. General Provisions and Tax Procedures Law, hereinafter referred to as the KUP
Law, is Law Number 6 of 1983 concerning General Provisions and Tax
Procedures as amended several times, last amended by Law Number 11 of 2020
concerning Job Creation.

3. Value Added Law, hereinafter referred to as the VAT Law, is Law Number 8 of
1983 concerning Value Added Tax on Goods and Services and Sales Tax on
Luxury Goods as amended several times, last amended by Law Number
4. Stamp Duty Law is Law Number 10 of 2020 concerning Stamp Duty.
5. Land and Building Tax Law, hereinafter referred to as the PBB Law, is Law Number
12 of 1985 concerning Land and Building Tax as amended by Law Number 12 of
1994.
6. Income Tax, hereinafter abbreviated to PPh, is Income Tax referred to in the

Income Tax Law.
7. Value Added Tax, hereinafter referred to as VAT, is Value Added Tax referred to in
the VAT Law.
8. Sales Tax on Luxury Goods, hereinafter referred to as STLGs, is Sales Tax on

Luxury Goods referred to in the VAT Law.
9. Stamp Duty is a tax on documents referred to in the Stamp Duty Law.
10. Land and Building Tax, hereinafter abbreviated to Land and Building Tax, is the
tax referred to in the Land and Building Tax Law.
11. Taxpayer Identification Number, hereinafter abbreviated to TIN, is a number

issued to Taxpayers as a means of tax administration that is used as a personal
identity or Taxpayer identity in conducting their tax rights and obligations.
12. Taxable Period is a period used as the basis for a Taxpayer to calculate, remit and
file taxes payable in a certain period as stipulated by the General Provisions and
Tax Procedures Law.
13. Tax Year is a period of 1 (one) calendar year unless a Taxpayer adopts an
accounting year that is different from the calendar year.
14. Taxable Object Number, hereinafter abbreviated to NOP, is the identification

number of a taxable object as a means of tax administration.
15. State Treasury is a place for storing state money stipulated by the Minister of
Finance as the State General Treasurer to accommodate all state revenues and
pay state expenditures.

16. State Revenue Module, hereinafter abbreviated to MPN is a revenue module that
contains a series of procedures ranging from the receipt, remittance, data
collection, recording, summarization to reporting in respect of State Revenues
and is an integrated system with the State Treasury and Budget System.
17. Tax Payment Bank is a commercial bank appointed by the Proxy of State General
Treasurer to receive remittances of State Revenue.
18. Foreign Exchange Tax Payment Bank is a commercial bank appointed by the
Minister of Finance to receive state revenue remittances in the context of exports
of and imports.
19. Foreign Currency Tax Payment Bank is a foreign exchange bank appointed by the
State General Treasurer/Proxy of State General Treasurer to receive remittances
of State Revenue in foreign currency.
20. Tax Payment Post Office is a Post Office appointed by the Proxy of State General
Treasurer to receive State Revenue remittances.
21. State Revenue Transaction Number, hereinafter abbreviated to NTPN, is the

number of proof of payment or remittance to the state treasury issued through
the state revenue module or by the state revenue system managed by the
Directorate General of Treasury.
22. Bank Transaction Number, hereinafter abbreviated to NTB, is the number of proof
of remittance of State Revenues issued by a Tax Payment Bank or Foreign
Currency Tax Payment Bank.
23. Postal Transaction Number, hereinafter abbreviated to NTP, is the number of

proof remittance of State Revenues issued by a Tax Payment Post Office.
24. Withholding Receipt Number, hereinafter abbreviated to NPP, is the number of

proof of state revenue transactions originating from Payment Order withholding.
25. State Revenue Receipt, hereinafter abbreviated to BPN, is a document issued by

a Collecting Agent for State Revenue transactions, that includes the State
Revenue Transaction Number and Bank Transaction Number/Postal Transaction
Number/Other Taxpayment Institution Transaction Number as other
administrative means equivalent to a payment slip.
26. Tax Payment Slip, hereinafter abbreviated to SSP, is a receipt of tax payment or
remittance using a specific form or other means to the state treasury, through a
place of payment appointed by the Minister of Finance.

27. Customs, Excise, and Tax Payment Slip in the context of imports, hereinafter
referred to as SSPCP, is a payment slip for state revenues in the context of
imports in the form of import duties, administrative fines, other customs
revenues, excise, other excise revenues, employment services, interest and
Import Article 22 Income Tax, Import VAT as well as Sales Tax on Imported Luxury
Goods.
28. Overbooking is a process of overbooking tax revenues to be recorded in the

appropriate tax revenues.
29. Overbooking Receipt, hereinafter referred to as Pbk Receipt, is receipt that

shows that an Overbooking has been carried out.
2. The provisions of paragraph (1), paragraph (3), paragraph (4), and paragraph (7) of
Article 7 are amended, and 1 (one) paragraph is added to Article 7, namely paragraph
(11), thereby, Article 7 reads as follows:
Article 7
(1) For small-scale business Taxpayers and Taxpayers in certain regions, the
settlement period referred to in Article 6 paragraph (1) may be extended to a
maximum of 2 (two) months.
(2) Small-scale business Taxpayers referred to in paragraph (1) consist of individual

Taxpayers and corporate Taxpayers.
(3) Small-scale business individual Taxpayers referred to in paragraph (2) must fulfil
the following criteria:
a. receiving income from a business, excluding income from services in

connection with independent personal services; and
b. having a gross turnover not exceeding IDR4,800,000,000.00 (four billion

and eight hundred million rupiah) in 1 (one) Tax Year.
(4) Small-scale business corporate Taxpayers referred to in paragraph (2) must fulfill
the following criteria:
a. Corporate Taxpayers excluding PEs; and

b. receiving income from a business with a gross turnover not exceeding
IDR4,800,000,000.00 (four billion and eight hundred million rupiah) in 1
(one) Tax Year.
(5) To obtain an extension of the settlement period referred to in paragraph (1),

small-scale business Taxpayers or Taxpayers in certain regions must apply for an
extension of the settlement period to the Director General of Taxes, no later than
9 (nine) working days prior to the payment due date using an application letter
for an extension of the settlement period.
(6) Based on the application of the Taxpayer referred to in paragraph (5), the
Director General of Taxes issues a decision within 7 (seven) working days after
the date the application is received.
(7) The decision referred to in paragraph (6) is in the form of:
a. approval; or
b. rejection of the Taxpayer's application.
(8) In the event that the Taxpayer’s application is approved as referred to in

paragraph (7) subparagraph a, the Director General of Taxes issues a decision
on the approval of the extension of the tax settlement period.
(9) In the event that the Taxpayer's application is rejected as referred to in paragraph
(7) subparagraph b, the Director General of Taxes issues a decision on the
rejection of the extension of the tax settlement period.
(10) If the period of 7 (seven) working days referred to in paragraph (6) has elapsed
and the Director General of Taxes does not issue a decision, the Taxpayer’s
application is deemed accepted.
(11) The approval decision referred to in paragraph (10) must be issued no later than
5 (five) working days after the 7 (seven) working day period ends.
3. Between paragraph (6) and paragraph (7) of Article 14, 2 (two) paragraphs are
inserted, namely paragraph (6a) and paragraph (6b), thereby, Article 14 reads as
follows:
Article 14
(1) Tax payment and remittance shall be carried out in Rupiah currency.

(2) Excluded from the provisions referred to in paragraph (1), Taxpayers that have
obtained a permit to maintain bookkeeping in English and in United States Dollar
currency shall pay Article 25 Income Tax, Article 29 Income Tax and Final Income
Tax self-paid by the Taxpayers as well as the notice of tax assessment and Notice
of Tax Collection issued in United States Dollar currency, using United States
Dollar currency.
(3) Included in the definition of a Taxpayer that has obtained a permit to maintain
bookkeeping in English and in United States Dollar currency referred to in
paragraph (2) is a Taxpayer that submits written notification of bookkeeping in
English and United States Dollar currency as stipulated under statutory tax
provisions.
(4) Payment of tax in United States Dollar referred to in paragraph (2) shall be made
to the state treasury through a Foreign Currency Tax Payment Bank.
(5) Taxpayers referred to in paragraph (2) may pay Article 25 Income Tax, Article 29
Income Tax and Final Income Tax self-paid by the Taxpayer in Rupiah.
(6) In the event that the tax payment is made in Rupiah currency as referred to in
paragraph (5), the Taxpayer must convert the payment into Rupiah currency to
United States Dollar currency using the exchange rate stipulated in the
applicable Minister of Finance Decree on the payment date.
(6a) In the event that the payment referred to in paragraph (2) is made through a Tax
Overpayment Refund Order deduction, the payment shall be made in Rupiah
using the exchange rate stipulated in the Decree of the Minister of Finance in
effect on the issuance date of the Preliminary Refunds Decision Letter.
(6b) In the event that the payment referred to in paragraph (2) is made through
Interest Compensation Payment withholding, the payment shall be made in
Rupiah using the exchange rate stipulated in the Minister of Finance Decree in
effect on the issuance date of the Calculation of Interest Compensation Decision
Letter.
(7) The provisions on procedures for the payment of Income Tax in United States
Dollar currency are stipulated by the Director General of Taxes Regulation or the
Director General of Treasury Regulation, either jointly or individually according to
their respective authorities.
4. The provisions of Article 21 are amended, thereby, it reads as follows:

Article 21
(1) Taxpayer’s application referred to in Article 20 must be submitted using an

application letter for payment of tax installments or an application letter for
deferral of tax payment.
(2) The application letter referred to in paragraph (1) shall be signed by the Taxpayer
and if it is signed by a non-Taxpayer, a special power of attorney must be
attached as stipulated under statutory tax provisions.
(3) The application letter referred to in paragraph (1) includes:
a. the amount of tax liability for which the payment is requested to be paid in
installments, the installment period and the amount of installments; or
b. the amount of tax liability for which payment is requested to be deferred

and the deferral period.
(4) The application letter referred to in paragraph (1) shall be attached with the
reasons and evidence of the liquidity crisis or circumstances beyond the control
of the Taxpayers as referred to in Article 20 in the form of interim financial
statements, financial statements or notes on gross turnover or revenues and/or
gross income.
(5) In the event that a Taxpayer applies for installment or deferral of the payment of
outstanding Land and Building Tax as referred to in Article 5, in addition to
fulfilling the requirements referred to in paragraph (1), paragraph (2), paragraph
(3) and paragraph (4), the Taxpayer must not have Land and Building Tax arrears
from the previous year and the application must also be attached with a copy of
the Notice of Tax Due, Notice of Land and Building Tax Assessment or Notice of
Land and Building Tax Collection for which the application for installment or
deferral is submitted.
(6) Application letter for installment of tax payment or application letter for tax
payment deferral referred to in paragraph (1) shall be submitted no later than:
a. when the Annual Tax Return is filed, for the tax underpayment referred to in
Article 3; and/or

b. before the Distress Warrant is notified by the Tax Bailiff to the Tax Bearer as
stipulated in statutory provisions on tax collection using a distress warrant,
for the tax payable referred to in Article 5 and outstanding tax referred to in
Article 6 paragraph (1).
(7) The application letter referred to in paragraph (1) shall be submitted:
a. electronically, through certain channels stipulated by the Director General

of Taxes; or
b. in writing.
(8) Application in writing referred to in paragraph (7) subparagraph b is submitted:
a. directly;
b. by post with proof of postage; or
c. through a forwarder or courier service company with proof of postage.
Article 22
(1) Taxpayers applying for installments or deferral of tax payments as referred to in

Article 20, must provide tangible assets as collateral, with the following criteria:
a. the tangible assets belong to the applicant Tax Bearer as evidenced by

proof of ownership of the tangible assets; and
b. the tangible assets are not being used as collateral for the applicant Tax
Bearer’s liabilities.
(2) Taxpayers applying for installments after the time limit referred to in Article 21
paragraph (6) must provide tangible assets as collateral as referred to in
paragraph (1) in the amount of tax liability for which the application for installment
of tax payments is submitted.
6. The provisions of paragraph (1) of Article 23 are amended, thereby, Article 23 reads as
follows:

Article 23
(1) After verifying the completeness of the application referred to in Article 21

paragraph (1), paragraph (2), paragraph (3), paragraph (4), paragraph (5) and the
period for submitting the application as referred to in Article 21 paragraph (6) and
after considering the collateral referred to in Article 22, the Director General of
Taxes issues a decision within 7 (seven) working days after the date the
application is received.
(2) The decision referred to in paragraph (1) may be in the form of:
a. approval of the amount of tax installments and/or the installment period or

the length of the deferral according to the Taxpayer’s application;
b. approval of a fraction of the tax installment amount and/or the installment

period or the length of the deferral requested by the Taxpayer; or
c. rejection of the Taxpayer’s application.
(3) In the event that the Taxpayer’s application is approved as referred to in

paragraph (2) subparagraph a or partially approved as referred to in paragraph (2)
subparagraph b, the Director General of Taxes issues a decision on the approval
of the installment of tax payments or a decision on the approval of the deferral of
tax payments.
(4) In the event that the Taxpayer's application is rejected as referred to in paragraph
(2) subparagraph c, the Director General of Taxes shall issue a decision on the
rejection of installments/deferral of tax payments.
(5) If the period of 7 (seven) working days referred to in paragraph (1) has elapsed
and the Director General of Taxes does not issue a decision, the application is
approved according to the Taxpayer’s application and the decision on the
approval of the installment of tax payments or the decision on the approval of the
deferral of tax payments must be issued no later than 5 (five) working days after
the 7 (seven) working day period ends.
Article 25

(1) Installments for tax underpayment referred to in Article 3, tax payable referred to
in Article 5 or outstanding tax referred to in Article 6 paragraph (1), may be
provided for:
a. a maximum of 24 (twenty-four) months from the issuance of the decision

on the approval of the installment of tax payments referred to in Article 23
paragraph (3) or paragraph (5) with installments of a maximum of 1 (one)
time in 1 (one) month, for application for outstanding tax installments
referred to in Article 6 paragraph (1);
b. a maximum of 24 (twenty-four) months from the issuance of the decision

on the approval of the installment of tax payments referred to in Article 23
paragraph (3) or paragraph (5) with installments of a maximum 1 (one) time
in 1 (one) month, for application for tax installment payable referred to in
Article 5; or
c. a maximum of the filing deadline for the Annual Income Tax Return in the
following Tax Year, with installments of a maximum of 1 (one) time in 1 (one)
month, for application for installments for tax underpayment based on the
Annual Income Tax Return referred to in Article 3.
(2) Deferral of tax underpayment referred to in Article 3, tax payable referred to in

Article 5 or outstanding tax referred to in Article 6 paragraph (1) may be granted
for:
a. a maximum of 24 (twenty-four) months from the issuance of the decision

on approval for deferral of tax payment referred to in Article 23 paragraph
(3) or paragraph (5), for applications for deferral of outstanding tax referred
to in Article 6 paragraph (1);
b. a maximum of 24 (twenty-four) months from the issuance of the decision

on the approval of the deferral of tax payment referred to in Article 23
paragraph (3) or paragraph (5), for application for deferment of payable
taxes referred to in Article 5; or
c. no later than the filing deadline for the Annual Income Tax Return in the
following Tax Year, for application for deferral of tax underpayment based on
the Annual Income Tax Return referred to in Article 3.

Article 30
(1) In the event that a Taxpayer is approved to install or defer the payment as
referred to in Article 23 paragraph (2) subparagraph a and subparagraph b and
the approval is not related to the Notice of Tax Collection, Notice of Tax Due,
Notice of Land and Building Tax Assessment and Notice of Land and Building Tax
Collection, the Taxpayer is subject to administrative penalties in the form of
interest at the monthly rate stipulated by the Minister of Finance of the amount of
outstanding tax and imposed for a maximum of 24 (twenty-four) months and part
of the month is calculated as 1 (one) full month as referred to in Article 19
paragraph (2) of the General Provisions and Tax Procedures Law, which is
calculated from the payment due date until the installment payment/settlement.
(2) In the event that a Taxpayer is approved to install or defer the payment as
referred to in Article 23 paragraph (2) subparagraph a and subparagraph b and
the approval is related to the Notice of Tax Due, Notice of Land and Building Tax
Assessment, and Notice of Land and Building Tax Collection, the Taxpayer is
subject to an administrative fine of 2% (two percent) a month as referred to in
Article 11 paragraph (3) of the Land and Building Tax Law which is calculated from
the due date until the payment day for a maximum of 24 (twenty-four) months.
9. Appendix III referred to in Article 32 paragraph (3) is amended to be AS listed in

Appendix XXVI which constitutes an integral part of this Ministerial Regulation.
Section Three
Tax Returns
Article 104

concerning Tax Returns (Official Gazette of the Republic of Indonesia of 2014 Number 1974)
as amended by Minister of Finance Regulation Number 9/PMK.03/2018 concerning
Amendments to the Minister of Finance Regulation Number 243/PMK.03/2014 concerning
Tax Returns (Official Gazette of the Republic of Indonesia of 2018 Number 180), are
amended as follows:

1. The provisions of number 1, number 2 and number 3 of Article 1 are amended,
thereby, Article 1 reads as follows:
Article 1
Referred to herein this Ministerial Regulation:
4. Income Tax, hereinafter abbreviated to PPh, is Income Tax referred to in the

Income Tax Law.
5. Value Added Tax, hereinafter abbreviated to VAT, is Value Added Tax referred to
in the VAT Law.
6. Sales Tax on Luxury Goods, hereinafter abbreviated to STLGs, is Sales Tax on

Luxury Goods referred to in the VAT Law
7. Taxpayer is any individual or entity, comprising taxpayer and withholding agent

having tax rights and obligations pursuant to statutory tax provisions.
8. Tax Return, hereinafter abbreviated to SPT, is a form used by a Taxpayer to file

the calculation and/or payment of taxes, taxable objects and/or non-taxable
objects and/or assets and liabilities pursuant to statutory tax provisions.
9. Annual Tax Return is a Tax Return for a Tax Year or a Fraction of a Tax Year.
10. Periodic Tax Return is a Tax Return for a Taxable Period.

11. A forwarder or courier service company is a company in the form of a legal entity
that provides certain types of mail delivery services, including the delivery of Tax
Returns to the Directorate General of Taxes.
12. Verification of the Receipt of Tax Return, hereinafter referred to as Tax Return
Verification, is a series of activities carried out to assess the completeness of Tax
Return completion and its attachments.
2. The provisions of paragraph (5) and paragraph (6) of Article 20 are amended, thereby,
Article 20 reads as follows:
Article 20
(1) Taxpayers may voluntarily rectify the Tax Return that has been filed by submitting
a written statement, provided that the Director General of Taxes has not
submitted:
a. the Tax Audit Notification Letter; or
b. the public Preliminary Investigation Notification Letter to the Taxpayer, the

Taxpayer’s representative, proxy, employee or adult family member.
(2) The written statement in the rectification to the Tax Return referred to in
paragraph (1) is prepared by providing a sign in the space provided in the Tax
Return stating that the Taxpayer concerned has rectified the Tax Return.
(3) In the event that the rectification to the Tax Return referred to in paragraph (1)
states a loss or overpayment, the rectification to the Tax Return must be
submitted no later than 2 (two) years prior to the expiration of the assessment.
(4) In the event that the Taxpayer receives a notice of tax assessment, Objection
Decision Letter, Notice of Tax Correction, Appeal Decision or Civil Review
Decision of the previous Tax Year or several preceding Tax Years, which states a
differrent tax loss from the set off tax loss In the Annual Tax Return to be rectified,
the Taxpayer may rectify the Annual Tax Return as referred to in paragraph (1)
within a period of 3 (three) months after receiving the notice of tax assessment,
Objection Decision Letter, Notice of Tax Correction, Appeal Decision or Civil
Review Decision.

(5) In the event that Taxpayers self-rectify Annual Tax Return which results in a larger
tax liability, they are subject to administrative penalties in the form of interest at
the monthly interest rate stipulated by the Minister of Finance of the amount of
tax due and is imposed for a maximum of 24 (twenty-four) months and part of the
month is calculated as 1 (one) full month as referred to in Article 8 paragraph (2)
(6) In the event Taxpayers self-rectify Periodic Tax Return which results in a larger tax
liability, they are subject to administrative penalties in the form of interest at the
monthly interest rate stipulated by the Minister of Finance of the amount of tax
due and is imposed for a maximum of 24 (twenty-four) months and part of the
month is calculated as 1 (one) full month as referred to in Article 8 paragraph (2a)
Section Four
Procedures for Audits
Article 105

concerning Procedures for Audits (Official Gazette of the Republic of Indonesia of 2013
Number 47) as amended by the Minister of Finance Regulation Number 184/PMK.03/2015
concerning Amendments to Minister of Finance Regulation Number 17/PMK.03/2013
concerning Procedures for Audits (Official Gazette of the Republic of Indonesia of 2015
Number 1468), are amended as follows:
1. Provisions of number 1 of Article 1 are amended, thereby, Article 1 reads as follows:
Article 1

2. Audit is a series of activities to collect and process data, information and/or
evidence conducted in an objective and professional manner based on auditing
standards to assess tax compliance in fulfilling tax obligations and/or for other
purposes to implement statutory tax provisions.
3. Field Audit is an Audit conducted at a Taxpayer’s residence or domicile, the

Taxpayer’s place of business or independent personal services and/or other
places deemed necessary by the tax auditors.
4. Office Audit is an Audit conducted at the office of the Directorate General of

Taxes.
5. Tax Auditor is a Civil Servant within the Directorate General of Taxes or a

professional appointed by the Director General of Taxes, who is given the
authority and responsibility to carry out the Audit.
6. Tax Auditor Identification is identification issued by the Director General of Taxes

constituting proof that the person whose name is listed on the identification card
is a Tax Auditor.
7. Audit Warrant, hereinafter abbreviated to SP2, is a warrant to conduct an Audit to

assess compliance with the fulfilment of tax obligations and/or for other purposes
to implement statutory tax provisions.
8. Field Audit Notification Letter is a notification letter concerning the

implementation of a Field Audit to assess compliance with the fulfilment of tax
obligations and/or for other purposes to implement statutory tax provisions.
9. Summons for an Office Audit is a summons regarding the conduct of an Office

Audit to assess compliance with the fulfilment of tax obligations and/or for other
10. Bookkeeping is a recording process conducted regularly to collect data and

financial information including assets, liabilities, equity, income and expenses,
and acquisition price and sales of goods or services resulting in financial
statements in the form of a balance sheet and income statement for such a Tax
Year.
11. Electronically managed data is data in electronic form, which is generated by a

computer and/or other electronic data processors and stored in diskettes,
compact disks, backup tapes, hard disks or other electronic storage media.

12. Books of Accounts, Records and Documents Storage Places are places
organized by Taxpayers, archives or document storage companies and/or those
organized by other parties.
13. Sealing is the act of placing a seal in a certain premises or room as well as
movable and/or immovable property which are used or reasonably suspected to
be used as a place or tool to store books of accounts or records, documents,
including electronically managed data and other objects.
14. Audit Working Paper, hereinafter abbreviated to KKP, is a detailed and clear
record prepared by the Tax Auditors concerning Audit procedures, data,
information and/or collected evidence, performed tests and conclusions drawn in
respect of the Audit implementation.
15. Notification of Tax Audit Findings, hereinafter abbreviated to SPHP, is a letter

containing Audit findings which include corrected accounts, correction values,
basis for correction, temporary calculation of the principal amount of tax payable
and temporary calculation of administrative
16. Closing Conference is a conference between the Taxpayer and the Tax Auditors
on Audit findings, the results of which are stated in the minutes of the final
closing conference of Audit findings which are signed by both parties and contain
corrections to the principal tax payable, either those approved or disapproved
and the calculation of administrative penalties.
17. Audit Quality Assurance Team is a team established by the Director General of
Taxes to discuss Audit findings that are limited to the legal basis for corrections
that have not been agreed upon between the Tax Auditors and the Taxpayer in
the Closing Conference to produce a quality Audit.
18. Audit Findings Report, hereinafter abbreviated to LHP, is a report containing the
implementation and findings of an Audit compiled by the Tax Auditor in a concise
and clear manner and pursuant to the scope and objectives of the Audit.
19. Summarized Audit Findings Report, hereinafter referred to as Summarized LPHP,

is a report on the termination of the Audit without any proposed issuance of a
notice of tax assessment.
20. Preliminary Investigation is an Audit conducted to find Preliminary Evidence of

whether an alleged Tax Crime has occurred.

21. Repeated Audit is an Audit conducted on a Taxpayer for whom a notice of tax
assessment has been issued based on prior Audit findings for the same type of
tax and Taxable Period, a Fraction of a Tax Year or Tax Year.
22. Audit Questionnaire is a form containing a number of questions and

assessments by the Taxpayer in respect of the implementation of an Audit.
23. Risk Analysis is an activity carried out to assess the level of Taxpayers’ non-
compliance at risk of causing a loss of potential tax revenues.
2. The provisions of paragraph (1) of Article 4 are amended and between paragraph (1)
and paragraph (2) of Article 4, 1 (one) paragraph is inserted, namely paragraph (1a),
Article 4
(1) An audit to assess the compliance with the fulfilment of tax obligations referred to
in Article 2, is carried out if the following criteria are fulfiled:
a. Taxpayers applying for tax refunds as referred to in Article 17B of the

General Provisions and Tax Procedures Law;
b. there is concrete data that causes the tax payable to be unpaid or

underpaid;
c. the Taxpayers file a Tax Return stating overpayment, other than those
applying for tax refunds as referred to in subparagraph a;
d. the Taxpayers that have been granted preliminary tax refunds;
e. the Taxpayers file a Tax Return stating a loss;
f. the Taxpayers perform a merger, consolidation, spin-off, liquidation,

dissolution or will leave Indonesia for good;
g. the Taxpayers change the accounting year or bookkeeping method or due

to the revaluation of fixed assets;
h. the Taxpayers do not file or file the Tax Return but past the period specified
in the reprimand letter selected to be Audited based on the Risk Analysis;

j. the Taxable Persons for VAT Purposes have not performed supplies of
Taxable Goods and/or Taxable Services and/or exports of Taxable Goods
and/or Taxable Services and have been granted Input VAT refunds or have
credited Input VAT as referred to in Article 9 paragraph (6e) of the 1984
Value Added Tax Law and the amendments thereto.
(1a) Concrete data referred to in paragraph (1) subparagraph b is data obtained or

held by the Director General of Taxes in the form of:
a. result of clarification or confirmation of tax invoices;
b. Income Tax withholding receipt;
c. tax data in respect of Taxpayers that do not file the Tax Return within the
period referred to in Article 3 paragraph (3) of the General Provisions and
Tax Procedures Law and after being reprimanded in writing, the Tax Return
is not filed on time as specified in the Reprimand Letter; and/or
d. proof of transaction or tax data that can be used to calculate the Taxpayers’
tax liabilities.
(2) The provisions on Risk Analysis referred to in paragraph (1) subparagraph h and
subparagraph i are implemented pursuant to statutory provisions.
3. The provisions of paragraph (2), paragraph (3), and paragraph (4) of Article 5 are
Article 5
(1) The Audit to assess compliance with the fulfilment of tax obligations referred to in
Article 4 is carried out in a Field Audit or Office Audit.
(2) Audit with the criteria referred to in Article 4 paragraph (1) subparagraph a is
carried out in the form of an Office Audit, in the event that the application for tax
refunds is submitted by a Taxpayer that fulfils the following requirements:
a. the Taxpayer's financial statement for the audited Tax Year is audited by a
public accountant or the financial statement of one of the Tax Years of the
2 (two) Tax Years before the audited Tax Year has been audited by a public
accountant with an unqualified opinion; and

b. the Taxpayer is not being subject to Preliminary Investigations,
Investigations or Tax Crime Prosecution and/or the Taxpayer in the last 5
(five) years have never been sentenced for a tax crime.
(3) Audits with the criteria referred to in Article 4 paragraph (1) subparagraph b is
conducted in the form of an Office Audit.
(4) Audits with the criteria referred to in Article 4 paragraph (1) subparagraph c to
subparagraph g and subparagraph j are conducted in the form of an Office Audit
or a Field Audit.
(5) Audits with the criteria referred to in Article 4 paragraph (2) subparagraph h and
subparagraph i are conducted in the form of a Field Audit.
(6) In the event that in an Office Audit, indications of transactions related to transfer
pricing and/or other special transactions are found indicating the existence of
manipulation of financial transactions, the implementation of the Office Audit is
changed to a Field Audit.
Article 11
In conducting an Audit to assess compliance with the fulfilment of tax obligations, Tax
Auditors must:
a. submit a Field Tax Audit Notification Letter to the Taxpayer in the event that the
Audit is conducted with a Field Audit type or a Summons for an Office Audit in the
event that the Audit is conducted in the form of an Office Audit;
b. show the Tax Auditor Identification and Audit Warrant to the Taxpayer when
conducting the Audit;
c. show a letter containing changes to the Tax Auditor team to the Taxpayer if the
membership structure of the Tax Auditor team changes;
d. hold a meeting with the Taxpayer to explain:
1) the reasons and objectives of the Audit;
2) the Taxpayer’s rights and obligations during and after the Audit;

3) the Taxpayer’s right to apply for a conference with the Audit Quality
Assurance Team in the event that there are Audit findings that are limited
to the legal basis for corrections that have not been agreed upon between
the Tax Auditors and the Taxpayer in the Closing Conference, except for
Audits of concrete data conducted in Office Audits as referred to in Article 5
paragraph (3); and
4) the Taxpayer’s obligation to fulfil the request for books of accounts, records
and/or documents constituting the basis for the bookkeeping or recording
and other documents, which are borrowed from the Taxpayer;
e. outline the results of the meeting referred to in subparagraph d in the minutes of

the meeting with the Taxpayers;
f. submit the Notification of Tax Audit Findings to the Taxpayers;
g. grant the right to attend to the Taxpayers in the context of the Closing
Conference at the specified time;
h. submit the Audit Questionnaire to the Taxpayers;
i. guide the Taxpayers in fulfiling their tax obligations pursuant to statutory tax
provisions by submitting written advice;
j. return books of accounts, records and/or documents constituting the basis for
bookkeeping or recording and other documents borrowed from the Taxpayers;
and
k. keeping the confidentiality of everything that is known or notified to them by the

Taxpayers in the context of the Audit from other ineligible parties.
Article 13
In the implementation of an Audit to assess compliance with the fulfilment of tax

obligations, the Taxpayers are entitled to:
a. ask the Tax Auditors to show the Tax Auditor Identification and Audit Warrant;
b. ask the Tax Auditors to provide a Field Tax Audit Notification Letter in the event
that the Audit is conducted in a Field Audit;

c. ask the Tax Auditors to show a letter outlining changes to the Tax Auditor team if
the membership structure of the Tax Auditor team changes;
d. ask the Tax Auditors to explain the reasons and objectives of the Audit;
e. receive the Notification of Tax Audit Findings;
f. attend the Closing Conference at the specified time;
g. apply for a discussion with the Audit Quality Assurance Team, in the event that
there are Audit findings that are limited to the legal basis for corrections that have
not been agreed upon between the Tax Auditors and the Taxpayer in the Closing
Conference, except for Audits of concrete data conducted in the form of an
Office Audit as referred to in Article 5 paragraph (3); and
h. provide an opinion or assessment on the implementation of the Audit by the Tax

Auditors by completing the Audit Questionnaire.
6. The provisions of paragraph (4), paragraph (5) and paragraph (6) of Article 15 are
Article 15
(1) Audits to assess compliance with the fulfilment of tax obligations are conducted
within the Audit period that includes:
a. the assessment period; and
b. the Closing Conference and reporting period.
(2) If an Audit is conducted in the form of a Field Audit, the assessment period
referred to in paragraph (1) subparagraph a is a maximum of 6 (six) months,
which is calculated from the time the Field Tax Audit Notification Letter is
submitted to the Taxpayer, the Taxpayer’s representative, proxy, employee or
adult family member, until the date the Notification of Tax Audit Findings is
adult family member.

(3) If an Audit is conducted in the form of an Office Audit, the assessment period
referred to in paragraph (1) subparagraph a is a maximum of 4 (four) months,
which is calculated from the date the Taxpayer, the Taxpayer’s the Taxpayer’s
representative, proxy, employee or adult family member fulfils the Summons for
an Office Audit until the date the Notification of Tax Audit Findings is submitted to
the Taxpayer, the Taxpayer’s representative, proxy, employee or adult family
member.
(4) If an Audit of concrete data is conducted in the form of an Office Audit as referred
to in Article 5 paragraph (3), the assessment period referred to in paragraph (1)
subparagraph a is a maximum of 1 (one) month, which is calculated from the date
the Taxpayer, the Taxpayer’s representative or proxy appears to fulfil the
Summons for an Office Audit until the date the Notification of Tax Audit Findings is
adult family member.
(5) The Closing Conference and reporting period referred to in paragraph (1)
subparagraph b is a maximum of 2 (two) months, calculated from the date the
Notification of Tax Audit Findings is submitted to the Taxpayer, the Taxpayer’s
representative, proxy, employee or adult family member until the date of the Audit
Findings Report.
(6) If the Audit of concrete data is conducted in the form of an Office Audit as
referred to in Article 5 paragraph (3), the Closing Conference and reporting
period referred to in paragraph (1) subparagraph b is a maximum of 10 (ten)
working days, calculated from the date of Notification of Tax Audit Findings is
adult family member until the date of the Audit Findings Report.
7. Provisions of paragraph (1) of Article 17 are amended, thereby, Article 17 reads as

follows:
Article 17
(1) The assessment period of the Office Audit referred to in Article 15 paragraph (3),
may be extended for a maximum of 2 (two) months, except for the Audit of
concrete data conducted in the form of an Office Audit as referred to in Article 5
paragraph (3) cannot be extended.

(2) Assessment period of the Office Audit referred to in paragraph (1) is extended in
the event that:
a. the Office Audit is extended to another Taxable Period, a Fraction of a Tax

Year or Tax Year;
b. there is a confirmation or request for data and/or information to a third

party;
c. the scope of the Office Audit covers all types of taxes; and/or
d. based on the consideration of the head of the Audit implementing unit.
8. Provisions of Article 21 are amended, thereby, it reads as follows:
Article 21
An Audit is completed by preparing a Summarized Audit Findings Report as referred to

in Article 20 subparagraph a in the event that:
a. the Taxpayer, the Taxpayer’s representative, proxy, employee or adult family

member being audited
1) is not found within 6 (six) months from the date the Field Tax Audit
Notification Letter is issued; or
2) does not fulfil the Audit summons within a period of 4 (four) months from
the date the Summons for an Office Audit is issued;
b. the Field Audit or Office Audit is suspended because it is followed up with a public
Preliminary Investigation and the public Preliminary Investigation:
1) does not proceed with an investigation because the Taxpayers disclose

the incorrectness of their actions as referred to in Article 8 paragraph (3) of
the General Provisions and Tax Procedures Law;
2) deleted;
3) proceeds with an investigation but the investigation is terminated because

there is no prosecution as referred to in Article 44B of the General
Provisions and Tax Procedures Law;

4) proceeds with an investigation but the investigation is terminated because
the incident has expired as referred to in Article 44A of the General
5) proceeds with an investigation and prosecution and there has been a

Court Decision concerning a tax crime with permanent legal force stating
that the Taxpayer is legally and convincingly proven guilty of committing a
tax crime and a copy of the Court Decision has been received by the
Director General of Taxes;
c. the Field Audit or Office Audit is suspended because it is followed up with an

investigation as a follow-up to the restricted Preliminary Investigations and the
investigation:
1) is terminated as it fulfils provisions referred to in Article 44B of the General

2) proceeds with prosecution and there has been a Court Decision

concerning a tax crime with permanent legal force stating that the Taxpayer
is legally and convincingly proven guilty of committing a tax crime and a
copy of the Court Decision has been received by the Director General of
Taxes; or
d. The Repeated Audit does not result in an additional tax that has been stipulated
in the previous notice of tax assessment.
9. Between Article 21 and Article 22 1 (one) article is inserted, namely Article 21A,
thereby, it reads as follows:
Article 21A
Excluded from the provisions referred to in Article 21 subparagraph b number 1),

subparagraph b number 3), and subparagraph c number 1), an Audit is completed by
preparing an Audit Findings Report as referred to in Article 20 subparagraph b, in the
event that based on the results of Preliminary Investigations or the results of tax crime
investigations, there remains a tax overpayment.

Article 22
(1) Audit completed by preparing an Audit Findings Report as referred to in Article 20

subparagraph b, is carried out in the event that:
a. the Taxpayer, the Taxpayer’s representative, proxy, employee or adult

family member being Audited is found or fulfils the Audit summons and the
Audit can be completed within the Audit period;
b. the Taxpayer, the Taxpayer’s representative, proxy, employee or adult

family member being Audited is found or fulfils the Audit summons and the
assessment of compliance with the fulfilment of tax obligations cannot be
completed until:
1) the end of the extension of the Field Audit assessment period

referred to in Article 16 paragraph (1) or paragraph (3); or
2) the end of the extension of the Office Audit assessment period

referred to in Article 17 paragraph (1);
c. the Taxpayer, the Taxpayer’s representative, proxy, employee or adult

family member being Audited in respect of the application for tax refunds
referred to in Article 17B of the General Provisions and Tax Procedures Law:
1) is not found within 6 (six) months from the date the Field Tax Audit
Notification Letter is issued; or
2) does not fulfil the Audit summons within a period of 4 (four) months
from the date the Summons for an Office Audit is issued;
d. the Taxpayer, the Taxpayer’s representative, proxy, employee or adult

family member being Audited for concrete data in an Office Audit as referred
to in Article 5 paragraph (3) does not fulfil the Audit summons within 1 (one)
month from the date the Summons for an Office Audit is issued;
e. the Field Audit or Office Audit is suspended because it is followed up with a

public Preliminary Investigation and the public Preliminary Investigation:
1) is terminated because the individual Taxpayer subject to the public

Preliminary Investigation passes away;
2) is terminated because there is no preliminary evidence of a tax crime;

3) proceeds with an investigation but the investigation is terminated
because there is insufficient evidence or the incident is not a tax
crime or the suspect passes away referred to in Article 44A of the
General Provisions and Tax Procedures Law; or
4) proceeds with an investigation and prosecution and there has been a

Court Decision concerning a tax crime with permanent legal force with
a verdict of not guilty or released from all charges and a copy of the
Court Decision has been received by the Director General of Taxes;
or
f. the Field Audit or Office Audit is suspended because it is followed up with

an investigation as a follow-up to the restricted Preliminary Investigations
and the investigation:
1) is terminated because there is insufficient evidence or the incident is

not a tax crime or the suspect passes away as referred to in Article
44A of the General Provisions and Tax Procedures Law; or
2) proceeds with prosecution and there has been a Court concerning a

tax crime with permanent legal force with a verdict of not guilty or
released from all charges and a copy of the Court Decision has been
received by the Director General of Taxes.
(2) Field Audit or Office Audit for which the assessment has not been completed as
referred to in paragraph (1) subparagraph b, must be completed by submitting
the Notification of Tax Audit Findings within a maximum period of 7 (seven)
working days from the end of:
a. the extension of the Field Audit assessment period referred to in Article 16

paragraph (1) or paragraph (3); or
b. the extension of the Office Audit assessment period referred to in Article 17

paragraph (1), and proceeds to the Audit stage until the preparation of the
Audit Findings Report.
(3) If the Taxpayer, the Taxpayer’s representative or proxy being Audited on

concrete data in in the form of an Office Audit as referred to in Article 5 paragraph
(3) does not fulfil the Audit summons, the Audit must be completed by
submitting the Notification of Tax Audit Findings within a maximum period of 3
(three) working days after the expiration of the 1 (one) month period referred to
in paragraph (1) subparagraph d.

follows:
Article 41
(1) The findings of the Audit to assess compliance with the fulfilment of tax
obligations must be notified to the Taxpayer through the submission of
Notification of Tax Audit Findings which is attached with the list of Audit findings.
(2) Notification of Tax Audit Findings and the list of Audit findings referred to in
paragraph (1) shall be submitted by the Tax Auditors directly or by facsimile.
(3) In the event that the Notification of Tax Audit Findings is submitted directly and
the Taxpayer, the Taxpayer’s representative or proxy refuses to receive the
Notification of Tax Audit Findings, the Taxpayer, the Taxpayer’s representative or
proxy must sign a letter of refusal to receive the Notification of Tax Audit Findings.
(4) In the event that the Taxpayer, representative, or the Taxpayer's proxy refuses to
sign the letter of refusal to receive the Notification of Tax Audit Findings referred
to in paragraph (3), the Tax Auditors shall prepare an official report on the refusal
to receive the Notification of Tax Audit Findings which is signed by the Tax Auditor
Team
(5) In the event that the Audit of concrete data is conducted in an Office Audit as
referred to in Article 5 paragraph (3), the Notification of Tax Audit Findings
referred to in paragraph (1) shall be submitted simultaneously with the
submission of a written invitation to attend the Closing Conference.
12. The provisions of paragraph (5) Article 42 are amended, thereby, Article 42 reads as
follows:
Article 42
(1) Taxpayers must provide a written response to the Notification of Tax Audit
Findings and the list of Audit findings referred to in Article 41 paragraph (1) in the
form of:

a. audit finding approval statement sheet in the event that the Taxpayer
approves all Audit findings; or
b. rebuttal letter, in the event that the Taxpayer does not approve part or all of
Audit findings.
(2) The written response referred to in paragraph (1) must be submitted within a
maximum period of 7 (seven) working days from the date the Notification of Tax
Audit Findings is received by the Taxpayer.
(3) Taxpayers may extend the submission period of the written response referred to
in paragraph (2) for a maximum period of 3 (three) working days since the period
referred to in paragraph (2) ends.
(4) To extend the submission period of the response referred to in paragraph (3),
the Taxpayers must submit written notice before the period referred to in
paragraph (2) ends.
(5) In the event that the Audit of concrete data is conducted in the form of an Office
Audit as referred to in Article 5 paragraph (3), the written response referred to in
paragraph (1) is submitted no later than when the Taxpayer must fulfill the written
invitation to attend the Closing Conference and the Taxpayer cannot extend the
submission period of the written response.
(6) The written response referred to in paragraph (1) and written notice referred to in
paragraph (4) are submitted by the Taxpayer directly or by facsimile.
(7) In the event that the Taxpayer does not submit a written response to the
Notification of Tax Audit Findings, the Tax Auditors prepare an official report on
the non-submission of a written response to the Notification of Tax Audit Findings
which is signed by the Tax Auditor team.
follows:
Article 43
(1) To carry out the discussion on Audit findings stated in the Notification of Tax
Audit Findings and the list of Audit findings referred to in Article 41 paragraph (1),
the Taxpayer must be given the right to attend the Closing Conference.

(2) The right to attend referred to in paragraph (1), is granted by sending a written
invitation to the Taxpayer by stating the day and date of the Closing Conference.
(3) The invitation referred to in paragraph (2) must be submitted to the Taxpayer
within a maximum period of 3 (three) working days as of:
a. the receipt of the written response to the Notification of Tax Audit Findings
from the Taxpayer according to the period referred to in Article 42
paragraph (2) or paragraph (3); or
b. the end of the period referred to in Article 42 paragraph (3), in the event
that the Taxpayer does not submit a written response to the Notification of
Tax Audit Findings.
(4) If the Audit of concrete data is conducted in the form of an Office Audit as
referred to in Article 5 paragraph (3), a written invitation to attend the Closing
Conference is submitted together with the submission of the Notification of Tax
Audit Findings.
(5) The invitation referred to in paragraph (2) may be submitted by the Tax Auditors
directly or by facsimile.
Article 61
(1) Taxpayers may disclose in a separate report in writing the incorrect completion of
the Tax Return that has been filed according to the actual situation referred to in
Article 8 paragraph (4) of the General Provisions and Tax Procedures Law and
Article 8 of Government Regulation Number 74 of 2011 and the amendments
thereto insofar as that the Tax Auditors have not submitted the Notification of Tax
Audit Findings.
(2) Disclosure of the incorrect completion of the Tax Return referred to in paragraph
(1) shall be submitted to the Tax Office where the Taxpayer is registered.
(3) The separate report in writing referred to in paragraph (1) must be signed by the
Taxpayer, the Taxpayer’s representative or proxy and attached with:

a. the calculation of underpaid tax according to the actual situation in the
format of the Tax Return;
b. the Tax Payment Slip for the payment of underpaid tax; and
c. the Tax Payment Slip for the payment of administrative penalties in the form
of interest as referred to in Article 8 paragraph (5) of the General Provisions
and Tax Procedures Law.
(4) If the disclosure of incorrect Tax Return completion referred to in paragraph (1)
does not result in a tax underpayment, the disclosure does not need to be
attached with the Tax Payment Slip.
15. The provisions of paragraph (5) Article 62 is amended and paragraph (7) Article 62 is
deleted, thereby, Article 62 reads as follows:
Article 62
(1) To prove the disclosure of incorrectness in a separate report as referred to in

Article 61 paragraph (1), the Audit will continue and based on Audit findings, a
notice of tax assessment is issued by considering the separate report and taking
into account the paid tax principal.
(2) In the event that the Audit findings referred to in paragraph (1) prove that the
disclosure of incorrect completion of the Tax Return by the Taxpayer is not in
accordance with the actual situation, a notice of tax assessment is issued
according to the actual situation.
(3) In the event that the Audit findings referred to in paragraph (1) prove that the
disclosure of incorrect completion of the Tax Return by the Taxpayer is in
accordance with the actual situation, a notice of tax assessment is issued
according to the Taxpayer’s disclosure.
(4) The Tax Payment Slip referred to in Article 61 paragraph (3) subparagraph b is
calculated as a tax credit in the notice of tax assessment issued based on the
Audit findings referred to in paragraph (1), paragraph (2) and paragraph (3).

(5) Tax Payment Slip referred to in Article 61 paragraph (3) subparagraph c
constitutes proof of payment of administrative penalties in the form of interest as
referred to in Article 8 paragraph (5) of the General Provisions and Tax
Procedures Law in respect of the disclosure of incorrect completion of the Tax
Return.
(6) Notice of tax assessment referred to in paragraph (2) is added with administrative
penalties pursuant to Article 13 of the General Provisions and Tax Procedures
Law.
(7) Deleted.
Article 64
(1) In the event that the proposed public Preliminary Investigation referred to in
Article 63 paragraph
(1) is approved by the competent authority, the Audit implementation is suspended

by preparing a report on the progress of the Audit until:
a. the public Preliminary Investigation is completed because the Taxpayer

discloses the incorrectness of actions as referred to in Article 8 paragraph
(3) of the General Provisions and Tax Procedures Law;
b. deleted;
c. the public Preliminary Investigation is terminated because the individual

Taxpayer subject to the public Preliminary Investigation passes away;
d. the public Preliminary Investigation is terminated because no preliminary

evidence of a tax crime is found;
e. the investigation is terminated pursuant to the provisions under Article 44A

of the General Provisions and Tax Procedures Law or Article 44B of the
f. the Court Decision on the tax crime already has permanent legal force and
a copy of the Court Decision has been received by the Director General of
Taxes.

(2) Audit suspension referred to in paragraph (1) must be notified in writing to the
Taxpayer.
(3) The written notification referred to in paragraph (2) shall be submitted together
with the submission of the notification of the public Preliminary Investigation.
(4) Books of accounts, records and documents related to the suspended Audit
referred to in paragraph (1) shall be submitted to the preliminary investigator by
preparing an official report signed by the Tax Auditors and the preliminary
investigator.
(5) A copy of the official report referred to in paragraph (4) shall be submitted to the
Taxpayer.
17. The provisions of paragraph (1) and paragraph (2) of Article 65 are amended and 1
(one) paragraph is added to Article 65, namely paragraph (3) thereby, Article 65 reads
as follows:
Article 65
(1) The suspended Audit referred to in Article 64 paragraph (1) shall proceed
pursuant to applicable provisions, if:
a. the public Preliminary Investigation is terminated because the individual

Taxpayer subject to the public Preliminary Investigation passes away;
b. the public Preliminary Investigation is terminated because no preliminary

evidence of a tax crime is found;
c. the public Preliminary Investigation proceeds with an investigation but the

investigation is terminated because there is insufficient evidence or the
incident is not a tax crime, or the suspect passes away as referred to in
Article 44A of the General Provisions and Tax Procedures Law; or
d. the public Preliminary Investigation proceeds with an investigation and

prosecution and there has been a Court Decision with permanent legal
force with a verdict of not guilty or released from all charges and a copy of
the Court Decision has been received by the Director General of Taxes.

(2) The suspended Audit referred to in Article 64 paragraph (1) is terminated by
preparing the Summarized Audit Findings Report referred to in Article 21
subparagraph b, if:
a. the public Preliminary Investigation is completed because the Taxpayers

disclose the incorrectness of their actions as referred to in Article 8
paragraph (3) of the General Provisions and Tax Procedures Law;
b. deleted;
c. the public Preliminary Investigation proceeds with an investigation but the

investigation is terminated because there is no prosecution as referred to
in Article 44B of the General Provisions and Tax Procedures Law;
d. the public Preliminary Investigation proceeds with an investigation but the

investigation is terminated because the incident has expired as referred to
in Article 44A of the General Provisions and Tax Procedures Law; and
e. the public Preliminary Investigation proceeds with an investigation and

prosecution and there has been a Court Decision on a tax crime with
permanent legal force stating that the Taxpayer is legally and convincingly
proven guilty of committing a tax crime and a copy of the Court Decision
has been received by the Director General of Taxes.
(3) Excluded from the provisions referred to in paragraph (2) subparagraph a and
subparagraph c, the suspended audit referred to in Article 64 proceeds in the
event that there remains tax overpayment based on preliminary investigation
results or investigation results.
18. The provisions of paragraph (4) and paragraph (5) of Article 66 are amended and (one)
paragraph is added to Article 66 namely paragraph (6), thereby, Article 66 reads as
follows:
Article 66
(1) In the event that the Taxpayer is Audited to assess compliance with the fulfilment
of tax obligations is also subject to a restricted Preliminary Investigation, the Audit
to assess compliance with the fulfilment of tax obligations is suspended by
preparing a progress report on the Audit if the restricted Preliminary
Investigations is followed up with an investigation.

(2) The Audit to assess compliance with the fulfilment of tax obligations referred to in
paragraph (1) is suspended until:
a. the investigation is terminated pursuant to Article 44A or Article 44B of the

b. the Court Decision on a tax crime with permanent legal force and a copy of
the decision has been received by the Director General of Taxes.
(3) Audit suspension referred to in paragraph (1) must be notified in writing to the
Taxpayer.
(4) The suspended Audit referred to in paragraph (1) proceeds if:
a. the investigation is terminated because there is insufficient evidence or the

incident is not a tax crime or the suspect passes away as referred to in
Article 44A of the General Provisions and Tax Procedures Law; or
b. the investigation proceeds with prosecution and Court Decisions on a tax

crime with permanent legal force with a verdict of not guilty or released from
all charges and a copy of the Court Decision has been received by the
(5) The suspended Audit referred to in paragraph (1) is terminated if:
a. the investigation is terminated due to Article 44B of the General Provisions

and Tax Procedures Law;
b. the investigation is terminated because the incident has expired as

referred to in Article 44A of the General Provisions and Tax Procedures Law;
or
c. the investigation proceeds with prosecution and Court Decision on a tax

crime permanent legal force other than that referred to in paragraph (4)
subparagraph b and a copy of the Court Decision has been received by the
(6) Excluded from the provisions referred to in paragraph (5) subparagraph a, the
suspended Audit referred to in Article 64 proceeds in the event that remains tax
overpayment based on investigation results.
follows:

Article 67
(1) In the event of a proceeded Audit as referred to in Article 65 paragraph (1) and
paragraph (3) or Article 66 paragraph (4) and paragraph (6), the assessment
period referred to in Article 15 or the extended assessment period referred to in
Article 16 or Article 17 is extended for a maximum period of 4 (four) months.
(2) In the event that the Audit is terminated as referred to in Article 65 paragraph (2)
or Article 66 paragraph (5), the Tax Auditors must submit a notice of termination
of the Audit to the Taxpayer.
(3) The Director General of Taxes may continue the Audit if after the Audit is
terminated as referred to in Article 65 paragraph (2) or Article 66 paragraph (5),
there are data other than those disclosed in Article 8 paragraph (3) of the
General Provisions and Tax Procedures Law or Article 44B of the General
Section Five
Procedures for the Issuance of the Notice of Tax Assessment and
Notice of Tax Collection
Article 106

concerning Procedures for the Issuance of Notice of Tax Assessment and Notice of Tax
Collection (Official Gazette of the Republic of Indonesia of 2012 Number 902) as amended
by the Minister of Finance Regulation Number 183/PMK.03/2015 concerning the
Procedures for the Issuance of Notice of Tax Assessment and Notice of Tax Collection
(Official Gazette of the Republic of Indonesia of 2015 Number 1467), are amended as
follows:
1. The provisions of number 1 and number 2 Article 1 are amended, thereby, Article 1
reads as follows:

Article 1
3. Notice of Tax Underpayment Assessment is a notice of tax assessment that

specifies the principal amount of tax payable, the amount of tax credit, the
principal amount of tax underpayment, the amount of administrative penalties
and total tax due.
4. Notice of Additional Tax Underpayment Assessment is a notice of tax

assessment that specifies an additional amount of tax payable over the
previously issued tax assessment.
5. Notice of Nil Tax Assessment is a notice of tax assessment that specifies the
principal amount of tax payable is equal to the amount of tax credit or there is no
tax payable and no tax credit.
6. Notice of Tax Overpayment Assessment is a notice of tax assessment that

specifies the amount of tax overpayment resulting from a greater amount of tax
credit than tax payable or the tax that should not otherwise be payable.

8. Repeated Audit is an Audit conducted on a Taxpayer for whom a notice of tax

assessment has been issued based on prior Audit findings for the same type of
tax and Taxable Period, a Fraction of a Tax Year or Tax Year.
9. Preliminary Investigation is an Audit conducted to find Preliminary Evidence of


2. The provisions of paragraph (2) and paragraph (3) of Article 2 are deleted, paragraph
(4), paragraph (5), paragraph (6) and paragraph (9) of Article 2 are amended and
between paragraph (8) and paragraph (9), 1 (one) paragraph is inserted, namely
paragraph (8a), thereby, Article 2 reads as follows
Article 2
(1) Within a period of 5 (five) years after the tax becomes payable or the end of a
Taxable Period, a Fraction of a Tax Year, or Tax Year the Director General of Taxes
may issue:
a. the Notice of Tax Underpayment Assessment; or
b. the Notice of Additional Tax Underpayment Assessment.
(2) Deleted.
(3) Deleted.
(4) Notice of Tax Underpayment Assessment is issued in the event that there is tax
that is not or underpaid based on:
a. Audit Findings of:
1. tax payable that is not or underpaid;
2. the Tax Return is not filed within the period referred to in Article 3
paragraph (3) of the General Provisions and Tax Procedures Law and
after being reprimanded in writing, it is not submitted on time as
specified in the Reprimand Letter;
3. Value Added Tax and Sales Tax on Luxury Goods that, in fact, should
not be set off against the tax difference or should not be subject to a
0% (zero percent) rate;
4. the obligations referred to in Article 28 of the General Provisions and

Tax Procedures Law or Article 29 of the General Provisions and Tax
Procedures Law are not fulfilled, thereby, the amount of tax liability
cannot be determined;

5. for the Taxpayer, a Taxpayer Identification Number is issued and/or
registered as a Taxable Person for VAT Purposes ex officio as referred
to in Article 2 paragraph (4a) of the General Provisions and Tax
Procedures Law; or
6. Taxable Persons for VAT Purposes do not perform supplies of Taxable

Goods and/or Taxable Services and/or exports of Taxable Goods
and/or Taxable Services and have been granted Input VAT refund or
have credited Input VAT as referred to in Article 9 paragraph (6e) of
the VAT Law; or
b. deleted.
(5) Notice of Additional Tax Underpayment Assessment is issued based on

Repeated Audit findings pursuant to statutory tax provisions.
(6) Repeated Audit referred to in paragraph (5) is conducted because of:
a. voluntary written statement from the Taxpayers as referred to in Article 15

paragraph (3) of the General Provisions and Tax Procedures Law;
b. deleted;
c. new data that results in an increase in the amount of tax payable, including
data previously undisclosed as referred to in Article 15 paragraph (1) of the
d. deleted.
(7) The Director General of Taxes issues a Notice of Nil Tax Assessment as referred
to in Article 17A paragraph (1) of the General Provisions and Tax Procedures Law
based on the Audit findings of the Tax Return if the amount of the tax credit or
the amount of tax paid is equal to the amount of tax payable or no tax is due and
there are neither tax credits nor tax payments.
(8) The Director General of Taxes issues a Notice of Tax Overpayment Assessment if
based on:
a. verification results of the correctness of tax payments for the application for
tax refunds that should not otherwise be payable as referred to in Article 17
paragraph (2) of the General Provisions and Tax Procedures Law there are
tax payments that should not otherwise be payable; or
b. Audit findings of:

1. the Tax Return contains a tax credit or the amount of tax paid is
greater than the amount of tax payable as referred to in Article 17
paragraph (1) of the General Provisions and Tax Procedures Law; or
2. the application for tax refunds as referred to in Article 17B of the

General Provisions and Tax Procedures Law states that the amount of
the tax credit or the amount of tax paid is greater than the amount of
tax payable.
(8a) Included in the tax overpayment referred to in paragraph (8) subparagraph b

number 2, Notice of Tax Overpayment Assessment may be issued, in the event
that based on the findings of a continued audit because:
a. the Preliminary Investigation is not followed up with an investigation as a

result of the incorrectness of the Taxpayer’s actions as referred to in Article
8 paragraph (3) of the General Provisions and Tax Procedures Law which is
in accordance with the actual situation, there remains tax overpayment; or
b. the investigation is terminated because the request for termination of the

investigation of the Taxpayer as referred to in Article 44B of the General
Provisions and Tax Procedures Law is received by the Attorney General,
there remains tax overpayment.
(9) Notice of Tax Overpayment Assessment referred to in paragraph (8) or paragraph

(8a) may continue to be issued if there is new data, including data previously
undisclosed, if the overpaid tax is, in fact, greater than the assessed tax
overpayment.
Article 3
(1) The notice of tax assessment referred to in Article 2 is issued for a Taxable
Period, a Fraction of a Tax Year or a Tax Year.
(2) The notice of tax assessment for a Fraction of a Tax Year or Tax Year referred to
in paragraph (1) is issued according to the Annual Income Tax Return.

(3) The notice of tax assessment for a Taxable Period referred to in paragraph (1) is
issued according to the Taxable Period covered by the Income Tax or Value
Added Tax Return.
(4) Excluded from the provisions referred to in paragraph (3), for the notice of tax
assessment on Article 21 Income Tax, 1 (one) notice of tax assessment is issued
for all Taxable Periods in 1 (one) calendar year.
(5) The notice of tax assessment referred to in paragraph (1) is issued according to
the Taxable Period, a Fraction of a Tax Year or the Tax Year the verification, Audit
or Repeated Audit is conducted.
follows:
Article 4
(1) The notice of tax assessment referred to in Article 2 must be issued based on
the tax calculation memo.
(2) The tax calculation memo referred to in paragraph (1) is prepared based on the
verification results report, Audit finding report or Repeated Audit finding report.
5. Between Article 4 and Article 5, 1 (one) article is inserted, namely Article 4A, thereby, it
reads as follows:
Article 4A
(1) The Director General of Taxes may issue a notice of tax assessment in the
electronic format and sign it electronically or issue a notice of tax assessment in
the written format and sign it normally, all of which have the same legal force.
(2) In the event that a notice of tax assessment is prepared in the electronic format,
a notice of tax assessment in the written format is not prepared.

follows:
Article 5
(1) The notice of tax assessment referred to in Article 2 must be delivered to the
Taxpayer.
(2) The notice of tax assessment referred to in paragraph (1), may be delivered:
a. directly;
b. by post with proof of postage;
c. through a forwarder or courier service company with proof of postage; or
d. electronically if the notice of tax assessment is issued electronically.
7. Article 6 is deleted
Article 7
The Director General of Taxes may issue a Notice of Tax Collection for a Taxable
Period, a Fraction of a Tax Year or a Tax Year in the event that:
a. Income Tax in the current year is not or underpaid;
b. based on verification results, there is a tax underpayment due to a typo and/or

miscalculation;
c. the Taxpayer is subject to administrative penalties in the form of a fine and/or

interest;
d. the entrepreneur that has been registered as a Taxable Person for VAT
Purposes, but does not prepare Tax Invoices or is late in preparing the Tax
Invoices;

e. the entrepreneur that has been registered as a Taxable Person for VAT Purposes
do not fill out the Tax Invoices completely as referred to in Article 13 paragraph
(5) and paragraph (6) of the VAT Law, other than the identity of the buyer of
Taxable Goods or the recipient of Taxable Services as well as the name and
signature as referred to in Article 13 paragraph (5) subparagraph b and
subparagraph g of the VAT Law in the event that the supply is performed by a
retailer Taxable Person for VAT Purposes;
f. deleted;
g. deleted; or
h. there is interest compensation that should not otherwise be granted to the

Taxpayer, if:
1. a decision is issued;
2. a decision is received; or
3. data or information is found,
indicating the existence of interest compensation that should not otherwise be

granted to the Taxpayer.
Article 8
Director General of Taxes may issue the Notice of Tax Collection referred to in Article 7
after:
a. verifying the tax administration data;
b. conducting an Audit; or
c. conducting a Repeated Audit.
10. Article 9 is deleted.

14. Between Article 12 and Article 13 1 (one) article is inserted, namely Article 12A,
Article 12A
(1) Notice of Tax Collection is issued no later than 5 (five) years after the tax
becomes payable or the end of the Taxable Period, a Fraction of a Tax Year or a
Tax Year.
(2) Notice of Tax Collection for Article 25 Income Tax referred to in Article 14
paragraph (1) subparagraph a of the General Provisions and Tax Procedures Law,
issued for unpaid or underpaid Income Tax in the current year as well as the
administrative penalties on Taxpayers that have not filed the Annual Income Tax
Return for the Tax Year concerned.
(3) Excluded from the provisions on issuance period referred to in paragraph (1):
a. Notice of Tax Collection for the administrative penalties referred to in Article 19

paragraph (1) of the General Provisions and Tax Procedures Law is issued no
later than according to the expiration date of collection of Notice of Tax
Underpayment Assessment and Notice of Additional Tax Underpayment
Assessment and Notice of Tax Correction, Objection Decision Letter, Appeal
Decision and Civil Review Decision, resulting in an increase in the amount of tax
payable;
b. Notice of Tax Collection for the administrative penalties referred to in Article 25

paragraph (9) of the General Provisions and Tax Procedures Law may be issued
no later than 5 (five) years from the issuance date of the Objection Decision
Letter, if the Taxpayer does not file an appeal; and

c. Notice of Tax Collection for the administrative penalties referred to in Article 27
paragraph (5d) of the General Provisions and Tax Procedures Law may be issued
no later than 5 (five) years from the date the Appeal Decision is pronounced by a
Tax Court judge in a public trial proceeding.
15. The provisions of paragraph (3) are amended, paragraph (5) of Article 13 is deleted,
Article 13
(1) The Director General of Taxes may issue a notice of tax assessment and/or
Notice of Tax Collection for a Taxable Period, a Fraction of a Tax Year or a Tax
Year before the Taxpayer is granted or issued a Taxpayer Identification Number
and/or registered as a Taxable Person for VAT Purposes, if data and/or
information is obtained indicating the existence of tax obligations that have not
been fulfiled by the Taxpayer.
(2) The Director General of Taxes may issue a notice of tax assessment and/or
Notice of Tax Collection for a Taxable Period, a Fraction of a Tax Year or a Tax
Year before and/or after the deregistration of the Taxpayer Identification Number
or the deregistration of a Taxable Person for VAT Purposes, if after the
deregistration of the Taxpayer Identification Number or the deregistration of the
Taxable Person for VAT Purposes, data and/or information is obtained indicating
the existence of tax obligations that have not been fulfiled by the Taxpayer.
(3) The notice of tax assessment and/or Notice of Tax Collection referred to in
paragraph (1) and/or paragraph (2) shall be issued within 5 (five) years after the
time the tax becomes payable or the end of the Taxable Period, a Fraction of a
Tax Year or a Tax Year as referred to in Article 2 and Article 12A.
(4) The notice of tax assessment and/or Notice of Tax Collection referred to in
paragraph (2) shall be issued by prior reactivation of the deregistered Taxpayer
Identification Number.
(5) Deleted.
16. Between Article 14 and Article 15, 1 (one) article is inserted, namely Article 14A,

Article 14A
(1) The Director General of Taxes may issue a Notice of Tax Collection in the
electronic format and sign it electronically or in the written format and sign it
normally, all of which have the same legal force.
(2) In the event that the Notice of Tax Collection is prepared in the electronic format,
the Notice of Tax Collection is not prepared in the written format.
(3) Notice of Tax Collection must be delivered to the Taxpayer.
(4) Notice of Tax Collection referred to in paragraph (3) may be delivered:
a. directly;
b. by post with proof of postage;
d. electronically if the Notice of Tax Collection is issued electronically.
Section Six
Procedures for Preliminary Tax Crime Investigations
Article 107
Several provisions under the Minister of Finance Regulation Number 239/PMK.03/2014

concerning Procedures for Preliminary Tax Crime Investigations (Official Gazette of the
Republic of Indonesia of 2014 Nomor 1951), are amended as follows:
1. The provisions of number 1 and number 3 Article 1 are amended, number 7 Article 1 is
deleted and number 24 is added, thereby, Article 1 reads as follows:
Article 1

2. Land and Building Tax Law, hereinafter referred to as the PBB Law, is Law Number
12 of 1985 concerning Land and Building Tax as amended by Law Number 12 of
1994.
3. Stamp Duty Law is Law Number 10 of 2020 concerning Stamp Duty.
4. Tax Collection Using Distress Warrant Law, hereinafter referred to as PPSP Law, is
Law Number 19 of 1997 concerning Tax Collection Using Distress Warrant as
amended by Law Number 19 of 2000.
5. Tax Crime is an act that is subject to criminal penalties by the laws in the field of
taxation which includes Article 38, Article 39, Article 39A, Article 41, Article 41A,
Article 41B, Article 41C and Article 43 of the General Provisions and Tax
Procedures Law, Article 24 and Article 25 of the Land and Building Tax Law, Article
13 and Article 14 of the Stamp Duty Law and Article 41A of the Tax Collection
Using Distress Warrant Law.

7. Deleted.
8. Preliminary Evidence is a condition, conduct and/or evidence in the form of

information, writings or objects that may strongly indicate a Tax Crime is occurring
or has occurred and been committed by anyone which may cause losses to
state revenues.
9. Preliminary Investigation is Audit conducted to find Preliminary Evidence of

10. Tax Crime Investigation, hereinafter referred to as Investigation, is a series of

activities conducted by an investigator to find and collect evidence to uncover a
Tax Crime and find the suspect.
11. Information is the information submitted orally or in writing that may be developed
and analysed to determine whether there is Preliminary Evidence or not.

12. Data is a collection of numbers, letters, words or images in the form of letters,
documents, books of account or records, either in the electronic or non-
electronic format, which may be developed and analysed to determine whether
there is Preliminary Evidence or not.
13. Report is the notification submitted by a person or institution due to rights and/or
obligations pursuant to the law to the competent authority concerning an alleged
occurrence or occurrence of a Tax Crime.
14. Complaint is a notification attached with a request by an interested party to the

competent authority to take legal measures against an individual or entity that
has committed a Tax Crime that harms the party.
15. Criminal Incident is an incident that contains a Tax Crime.
16. Evidence is books of accounts, records, documents, information, electronically

managed data and/or other objects, which may be used to find Preliminary
Evidence.
17. Implementing Unit of Preliminary Investigations is a unit authorized to conduct

Preliminary Investigations pursuant to statutory provisions.
18. Preliminary Investigation Warrant is a warrant issued by the head of the

Implementing Unit of Preliminary Investigation to conduct Preliminary
Investigations.
19. Revised Preliminary Investigation Warrant is a Preliminary Investigations Warrant

issued due to a change in the Preliminary Investigator team and/or substitute of
the Implementing Unit of Preliminary Investigation.
20. Sealing is the act of placing a seal in a certain premises or room as well as
movable and/or immovable property which are used or reasonably suspected to
be used as a place or tool to store books of accounts or records, documents,
including electronically managed data and other objects.
21. Preliminary Investigation Working Paper is the documentation prepared by

Preliminary investigators concerning the undertaken Preliminary Investigation
procedures, the collected Evidence, the conducted Tax Crime and the
conclusions drawn in respect of the Preliminary Investigation implementation.
22. Preliminary Investigation Report is a report prepared by the Preliminary

investigator that discloses the implementation, conclusions and
recommendations for follow-up of Preliminary Investigations.

23. Incident Report is a written report on the existence of a Criminal Incident which
contains sufficient Preliminary Evidence as a basis for conducting an
Investigation.
24. Tax Payment Slip is a receipt of tax payment or remittance using a specific form or
other means to the state treasury, through a place of payment appointed by the
Minister of Finance.
2. The provisions of Article 2 are amended by adding 2 (two) paragraphs, namely

paragraph (5) and paragraph (6), thereby, Article 2 reads as follows:
Article 2
(1) The Director General of Taxes is authorized to conduct Preliminary Investigations

based on Information, Data, Reports and Complaints.
(2) Information, Data, Reports and Complaints referred to in paragraph (1) received
or obtained by the Director General of Taxes, are developed and analysed
through intelligence activities or observations.
(3) Information, Data, Reports and Complaints with strong indications of a Tax Crime
found from the results of the development of Preliminary Investigations or
Investigations may be directly followed up with a Preliminary Investigation.
(4) Information, Data, Reports and Complaints referred to in paragraph (2) and
paragraph (3) in respect of a Taxable Period, a Fraction of a Tax Year or a Tax
Year, whether or not a notice of tax assessment has been issued, is followed up
with a Preliminary Investigations insofar as there are indications of a Tax Crime.
(5) Preliminary Investigations conducted after the issuance of the notice of tax
assessment referred to in paragraph (4) shall only be conducted on new data
other than those contained in the notice of tax assessment.
(6) Preliminary Investigations referred to in paragraph (1) may be carried out even
though the period of 5 (five) years has elapsed since the end of a Taxable Period,
a Fraction of a Tax Year or a Tax Year, insofar as the expiration of the Tax Crime
prosecution has not elapsed.

Article 5
(1) Preliminary investigators conduct a public Preliminary Investigation within a

maximum period of 12 (twelve) months from the date of submission of the
notification of the Preliminary Investigation until the date of the Preliminary
Investigation Report.
(2) Preliminary investigators conduct a restricted Preliminary Investigation within a

maximum period of 12 (twelve) months from the date the Preliminary
Investigation Order is received by the Preliminary investigators until the date of
the Preliminary Investigation Report.
(3) If the Preliminary investigators are unable to conduct Preliminary Investigations

within the period referred to in paragraph (1) or paragraph (2), the Preliminary
investigators may apply for an extension of the period to the head of the
Implementing Unit of Preliminary Investigation.
(4) Head of the Implementing Unit of Preliminary Investigation may grant an

extension of the period referred to in paragraph (3) for a maximum of 12 (twelve)
months from the expiration of the period referred to in paragraph (1) or
paragraph (2).
(5) Head of the Implementing Unit of Preliminary Investigation considers the

application for an extension of the period referred to in paragraph (3) by taking
into account:
a. deleted;
b. expiration of the Tax Crime prosecution; or
c. progress of the completion of the Preliminary Investigations.
Article 15

(1) Preliminary Investigators must submit the notification letter of the Preliminary
Investigation directly to the individual or entity subject to the Preliminary
Investigation in the event that the Preliminary Investigation is conducted publicly.
(2) In the event that a public Preliminary Investigation is conducted against an

individual, the Preliminary investigator submits a notification letter of the
Preliminary Investigation to the individual subject to the Preliminary Investigation,
an adult family member or proxy.
(3) In the event that a public Preliminary Investigation is conducted against an entity,
the Preliminary investigator submits a notification letter of the Preliminary
Investigation to the representative, proxy or employee of the entity subject to the
Preliminary Investigation.
(4) In the event that the submission of the notification letter referred to in paragraph
(2) and paragraph (3) cannot be carried out, the Preliminary investigator submits
the notification letter of the Preliminary Investigation:
a. by post with proof of postage;
b. by facsimile;
d. electronically.
5. The provisions of paragraph (1), paragraph (4) and paragraph (5) Article 23 are
amended, paragraph (3) is deleted and between paragraph (5) and paragraph (6), 1
(one) paragraph is inserted, namely paragraph (5a), thereby, Article 23 reads as
follows:
Article 23
(1) Individuals or entities as Taxpayers subject to a public Preliminary Investigation

may voluntarily disclose the incorrectness of their actions for a crime of:
a. not filing a Tax Return, thereby, thereby resulting in losses to state

revenues; or

b. filing a Tax Return whose contents are incorrect or incomplete or attach
information whose contents are incorrect, thereby, resulting in losses to
state revenues, as referred to in Article 38 or Article 39 paragraph (1)
subparagraph c and subparagraph d of the General Provisions and Tax
Procedures Law.
(2) Tax Return referred to in paragraph (1) is a form used by a Taxpayer to file the
calculation and/or payment of taxes, taxable objects and/or non-taxable objects
and/or assets and liabilities pursuant to statutory tax provisions, including:
a. the Annual Tax Return referred to in the General Provisions and Tax
Procedures Law;
b. the Periodic Returns referred to in the General Provisions and Tax

Procedures Law; and
c. the Taxable Object Notification Letter referred to in the Land and Building
Tax Law.
(3) Deleted.
(4) Individuals or entities as Taxpayers subject to a public Preliminary Investigation

may submit the incorrectness of actions for the crime referred to in paragraph (1)
insofar as the notification letter for the commencement of the Investigation has
not been submitted to the public prosecutor through official investigators of the
State Police of the Republic of Indonesia.
(5) In carrying out the incorrectness of actions for a criminal act referred to in
paragraph (1), individuals or entities as Taxpayers subject to a public Preliminary
Investigation must:
a. submit the incorrectness of its actions in writing and signed; and
b. attached with:
1. the calculation of the underpayment of the actual amount of tax

payable;
2. the Tax Payment Slip or other equivalent administrative means as

proof of settlement of the underpayment of the actual amount of tax
payable; and

3. the Tax Payment Slip or other equivalent administrative means as
proof of settlement of administrative penalties in the form of fines as
stipulated under Article 8 paragraph (3a) of the General Provisions
and Tax Procedures Law.
(5a) Payment of the actual amount of tax payable referred to in paragraph (5)
subparagraph b number 2 and payment of administrative penalties in the form of
fines referred to in paragraph (5) subparagraph b number 3 constitutes recovery
of losses to state revenues.
(6) Individuals or entities as Taxpayers subject to a Preliminary Investigation submit

the incorrectness of actions to the head of the Tax Office where the Taxpayers
are registered or where Taxable Objects are administered and the copy to the
head of the Implementing Unit of Preliminary Investigation.
6. The provisions of paragraph (1) and paragraph (3) of Article 25 are amended and
paragraph (2), paragraph (4) and paragraph (5) of Article 25 are deleted, thereby,
Article 25
(1) In the event that the Preliminary Investigation is followed up with an Investigation,
payment for the incorrectness of actions that do not fulfil the provisions referred
to in Article 23 paragraph (4), paragraph (5) and paragraph (6) and/or is not in
accordance with the actual situation, is taken into account as a deduction from
losses to state revenues at the Investigation stage.
(2) Deleted.
(3) Payments for the incorrectness of actions referred to in paragraph (1) are not
transferable or refundable by the Taxpayers.
(4) Deleted.
(5) Deleted.

Article 28
In the event that an individual or entity as a Taxpayer being Audited to assess

compliance with the fulfillment of tax obligations:
a. is subject to a public Preliminary Investigation; or
b. is subject to a restricted Preliminary Investigation which is followed up with an

Investigation, the Audit shall be suspended.
8. The provisions of paragraph (1) Article 30 are amended, thereby, Article 30 reads as
follows:
Article 30
(1) The results of the Preliminary Investigations outlined in the Preliminary

Investigation Report referred to in Article 29 are followed up with:
a. an Investigation in the event that sufficient Preliminary Evidence is found;
b. a written notification by the head of the Implementing Unit of Preliminary

Investigation to an individual or entity as a Taxpayer subject to the public
Preliminary Investigation that the investigation is not carried out in the event
that the incorrectness of the actions of an individual or entity as a Taxpayer
is in accordance with the actual situation;
c. deleted;
d. termination of Preliminary Investigations by the head of the Implementing

Unit of Preliminary Investigation in the event that an individual Taxpayer
under the Preliminary Investigations passes away; or
e. termination of Preliminary Investigations by the head of the Implementing

Unit of Preliminary Investigation in the event that no Preliminary Evidence of
a Tax Crime is found.
(2) In the event that the Preliminary Investigation is conducted publicly, the
termination of the Preliminary Investigations referred to in paragraph (1)
subparagraph d and subparagraph e is notified in writing by the head of the
Implementing Unit of Preliminary Investigation to an individual or entity or proxy.

Section Seven
Applications for the Termination of Tax Crime Investigations for Tax
Revenue Purposes
Article 108

concerning Applications for the Termination of Tax Crime Investigations for Tax Revenue
Purposes (Official Gazette of the Republic of Indonesia of 2016 Number 538) are amended
as follows:
1. The provisions of number 1 of Article 1 are amended, thereby, Article 1 reads as

follows:
Article 1
Law, is Law Number 6 of 1983 tentang General Provisions and Tax Procedures as
Creation.
2. Tax crime Investigation, hereinafter referred to as Investigation, is a series of

activities conducted by an investigator to find and collect evidence to uncover tax
crime and find the suspect.
follows:
Article 3

(1) The Taxpayer’s applications referred to in Article 2 paragraph (2) may be
submitted after the Taxpayer has paid the tax that is not or underpaid or which
should not otherwise be refunded and is added with administrative penalties in
the form of a fine of 3 (three) times the amount of tax not or underpaid or that
should not otherwise be refunded.
(2) Included in taxes paid by the Taxpayer referred to in paragraph (1) are taxes that
are not or underpaid or that should not otherwise be refunded as a result of:
a. issuance and/or use of Tax Invoices, proof of tax collection, withholding

receipt and/or proof of tax remittance, which are not based on actual
transactions; and/or
b. issuance of Tax Invoices before the Entrepreneur is registered as a Taxable

Person for VAT Purposes.
3. Between Article 11 and Article 12, 1 (one) article is inserted, namely Article 11A,
Article 11A
(1) Documents related to the termination of an Investigation may be prepared

electronically and signed electronically or prepared in writing and signed normally,
all of which have the same legal force.
(2) Documents referred to in paragraph (1) may be submitted:
a. directly;
b. by post or forwarder services with proof of postage; or
c. electronically.
4. The attachment referred to in Article 11 is amended as listed in Appendix XXVII which


CHAPTER V
TRANSITIONAL PROVISIONS
Article 109
(1) For domestically-sourced Dividends received or accrued by a Taxpayer since the entry
into force of Law Number 11 of 2020 concerning Job Creation, that are excluded from
Income Tax objects as referred to in Article 15 for which Income Tax withholding has
been carried out, an application for tax refunds which should not otherwise be payable
may be submitted.
(2) Application for tax refunds that should not otherwise be payable referred to in
paragraph (1) is carried out pursuant to the Minister of Finance Regulation concerning
procedures for tax refunds that should not otherwise be payable.
Article 110
(1) The certain period for Taxable Persons for VAT Purposes that Have Not Performed Any
Supply and have performed Input VAT crediting for acquisitions of capital goods before
2 November 2020, is stipulated pursuant to the provisions under this Ministerial
Regulation.
(2) In the event that Taxable Persons for VAT Purposes that Have Not Performed Any
Supply rectify the Periodic VAT Return in a Taxable Period before 2 November 2020
which causes the Periodic VAT Return to be overpaid, the provisions on the refunds of
Input VAT overpayment shall be pursuant to the provisions under this Ministerial
Regulation.
(3) Taxable Persons for VAT Purposes may apply for a reduction in the amount of tax
stated in the notice of tax assessment as stipulated under Article 36 paragraph (1)
subparagraph b of the General Provisions and Tax Procedures Law for notices of tax
assessment issued on 2 November 2020 until the entry into force of this Ministerial
Regulation on supplies of Taxable Goods and/or Taxable Services before an
Entrepreneur is registered as a Taxable Person for VAT Purposes provided that:
a. audit findings do not take into account Input VAT using the Input VAT crediting
guidelines referred to in Article 65; and
b. the Taxable Persons for VAT Purposes disapprove of the audit findings referred
to in subparagraph a.
Services from outside the Customs Area within the Customs Area collected with a tax
assessment as referred to in Article 68 issued before 2 November 2020 may be
credited by the Taxable Persons for VAT Purposes insofar as the provisions referred to
in Article 68 paragraph (1) are fulfiled and the amount of outstanding VAT includes the
tax principal and penalties stated in the tax assessment has been paid as of 2
November 2020.
Article 111
The granting of interest compensation and the application for the granting of interest
compensation that has not been completed until this Ministerial Regulation comes into
force, which is based on an assessment, decision or verdict, which is issued or pronounced:
a. before 2 November 2020, shall be completed pursuant to the provisions under the
Minister of Finance Regulation Number 226/PMK.03/2013 concerning Procedures for
the Calculation and Granting of Interest Compensation as amended several times, last
amended by the Minister of Finance Regulation Number 65/PMK.03/2018; or
b. after 2 November 2020, shall be completed pursuant to the provisions under this
Ministerial Regulation,
and the completion period for the granting of interest compensation is no later than 1 (one)
month from the date the application submitted since this Ministerial Regulation comes into
force, is received in full by the Tax Office.
Article 112
Applications for installments or deferral of tax payments that have not been completed until
this Ministerial Regulation comes into force, shall be settled pursuant to the provisions
stipulated in the Minister of Finance Regulation Number 242/PMK.03/2014 concerning
Procedures for the Payment and Remittance of Taxes.

Article 113
(1) For Input VAT that has been refunded or has been credited by Taxable Persons for VAT
Purposes that do not perform supplies of Taxable Goods, supplies of Taxable Services,
exports of Taxable Goods and/or exports of Taxable Services that should be refunded
as referred to in Article 9 paragraph (6e) of the VAT Law:
a. that has passed the refund deadline referred to in Article 9 paragraph (6f) of the
VAT Law; and
b. payment has not been made until 2 November 2020,
a Notice of Tax Underpayment Assessment referred to in Article 13 paragraph (1)

subparagraph f of the General Provisions and Tax Procedures Law shall be issued.
(2) Interest compensation that should not otherwise be granted and no refund has been
carried out by the Taxpayer until 2 November 2020 shall be collected by issuing a
Notice of Tax Collection as referred to in Article 14 paragraph (1) subparagraph h of the
General Provisions and Tax Procedures Law.
Article 114
Preliminary Investigations that have received approval for the extension of the Preliminary
Investigation period before this Ministerial Regulation comes into force, shall be completed
according to the period specified in the approval of the extension pursuant to the provisions
stipulated in the Minister of Finance Regulation Number 239/PMK.03/2014 concerning
Procedures for Preliminary Tax Crime Investigations.
Article 115

Applications for the termination of tax crime Investigations which have not been completed
until this Ministerial Regulation comes into force, shall be completed pursuant to the
provisions stipulated in the Minister of Finance Regulation Number 55/PMK.03/2016
concerning Applications for the Termination of Tax Crime Investigations for Tax Revenue
Purposes.
Article 116
(1) The imposition of administrative penalties on:
a. the notice of tax assessment or Notice of Tax Collection issued after 2 November
2020 containing administrative penalties in the form of interest, in which the
calculation of administrative penalties commences before 2 November 2020; or
b. the disclosure of incorrect Tax Return completion filed after 2 November 2020,
is calculated using the interest rate pursuant to the Minister of Finance Decree
stipulating the interest rate as the basis for calculating administrative penalties in the
form of interest and the provision of interest compensation applicable for November
2020;
(2) For the submission of:
a. the incorrectness of actions as referred to in Article 8 paragraph (3) of the

General Provisions and Tax Procedures Law; and
b. requests for the termination of investigations as referred to in Article 44B of the

General Provisions and Tax Procedures Law,
by Taxpayers since 2 November 2020, the administrative penalties are imposed

pursuant to the General Provisions and Tax Procedures Law; and
(3) Administrative penalties referred to in Article 14 paragraph (4) of the General Provisions
and Tax Procedures Law through the Notice of Tax Collection issued after 2 November
2020 are imposed pursuant to the General Provisions and Tax Procedures Law.

CHAPTER VI
CLOSING PROVISIONS
Article 117
When this Ministerial Regulation comes into force:
a. Minister of Finance Regulation Number 111/PMK.03/2010 concerning Procedures for

the Withholding, Remittance and Filing of Income Tax on Dividends Received or
Accrued by Resident Individual Taxpayers (Official Gazette of the Republic of Indonesia
of 2010 Number 278);
b. Minister of Finance Regulation Number 107/PMK.03/2017 concerning the

Determination of When Dividends Are Accrued and its Calculation Basis by Resident
Taxpayers for Equity Participation in Business Entities Overseas Other than Listed
Business Entities (Official Gazette of the Republic of Indonesia of 2017 Number 1043)
as amended by the Minister of Finance Regulation Number 93/PMK.03/2019
concerning the Amendment to the Minister of Finance Regulation Number
107/PMK.03/2017 concerning the Determination of When Dividends Are Accrued and
its Calculation Basis by Resident Taxpayers for Equity Participation in Business Entities
Overseas Other than Listed Business Entities (Official Gazette of the Republic of
Indonesia of 2019 Number 702); and
c. Minister of Finance Regulation Number 192/PMK.03/2018 concerning the

Implementation of Tax Crediting for Foreign-Sourced Income (Official Gazette of the
Republic of Indonesia of 2018 Number 1837),
remain in effect insofar as they do not contradict the provisions under this Ministerial
Regulation.
Article 118
When this Ministerial Regulation comes into force:
a. Minister of Finance Regulation Number 151/PMK.03/2013 concerning Procedures for

the Preparation or Replacement of Tax Invoices (Official Gazette of the Republic of
Indonesia of 2013 Number 1313);

b. Minister of Finance Regulation Number 226/PMK.03/2013 concerning Procedures for
the Calculation and Granting of Interest Compensation (Official Gazette of the Republic
of Indonesia of 2013 Number 1630) as amended several times, last amended by
Minister of Finance Regulation Number 65/PMK.03/2018 concerning the Second
Amendment to the Minister of Finance Regulation Number 226/PMK.03/2013
concerning Procedures for the Calculation and Granting of Interest Compensation
(Official Gazette of the Republic of Indonesia of 2018 Number 820); and
c. Minister of Finance Regulation Number 31/PMK.03/2014 concerning the Time of

Calculation and Procedures for the Refund of Input VAT that Has Been Credited and
Refunded for Taxable Persons for VAT Purposes Experiencing Production Failure
(Official Gazette of the Republic of Indonesia of 2014 Nomor 199),
are revoked and declared invalid.
Article 119
This Ministerial Regulation shall come into force on the date of promulgation.
For public cognizance, this Ministerial Regulation shall be promulgated by placement in the
State Gazette of the Republic of Indonesia.
Stipulated in Jakarta
on 17 February 2021
MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA,
signed
SRI MULYANI INDRAWATI
Promulgated in Jakarta
on 17 February 2021
DIRECTOR GENERAL OF LEGISLATION OF THE MINISTRY OF JUSTICE AND HUMAN RIGHTS,
signed
WIDODO EKATJAHJANA
STATE GAZETTE OF THE REPUBLIC OF INDONESIA OF 2021 NUMBER 153


Peraturan Menteri Keuangan Nomor - 18 - PMK.03 - 2021 (ENGLISH)

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Peraturan Menteri Keuangan Nomor - 18 - PMK.03 - 2021 (ENGLISH)

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MINISTER OF FINANCE OF THE REPUBLIC OF

THE IMPLEMENTATION OF LAW NUMBER 11 OF 2020 CONCERNING JOB

BY THE GRACE OF ALMIGHTY GOD

b. that to implement the provisions under Article 9 paragraph (13) subparagraph a,

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d. that based on the considerations referred to in letter a, letter b and letter c, it is

1. Article 17 paragraph (3) of the 1945 Constitution of the Republic of Indonesia;

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7. Presidential Regulation Number 57 of 2020 concerning the Ministry of Finance (State

8. Minister of Finance Regulation Number 145/PMK.03/2012 concerning Procedures for

9. Minister of Finance Regulation Number 17/PMK.03/2013 concerning Procedures for

10. Minister of Finance Regulation Number 239/PMK.03/2014 concerning Procedures for

11. Minister of Finance Regulation Number 242/PMK.03/2014 concerning Procedures for

12. Minister of Finance Regulation Number 243/PMK.03/2014 concerning Tax Returns

13. Minister of Finance Regulation Number 55/PMK.03/2016 concerning Applications for

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MINISTER OF FINANCE REGULATION CONCERNING THE IMPLEMENTATION OF LAW NUMBER

Referred to herein this Minister of Finance Regulation:

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11. Taxpayer Identiﬁcation Number, hereinafter abbreviated to TIN, is a number issued to

13. Indonesian Citizen, hereinafter abbreviated to WNI, is a native Indonesian person or a

15. Certiﬁcate of Indonesian Citizens Fulﬁling the Requirements to Become Resident

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18. Dividend is the share of profits received or accrued by shareholders.

21. Hajj Financial Management Agency, hereinafter abbreviated to BPKH, is an institution

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41. Interest Compensation Decision Letter, hereinafter abbreviated to SKPIB, is a decision

42. Calculation of Interest Compensation Decision Letter, hereinafter abbreviated to

43. Interest Compensation Payment Order, hereinafter abbreviated to SPMIB, is a letter

44. Preliminary Refunds Decision Letter, hereinafter abbreviated to SKPKPP, is a decision

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(1) An individual constituting a resident taxpayer is an Indonesian Citizen or a Foreign

(2) An individual who resides in Indonesia referred to in paragraph (1) subparagraph a is an

a. resides in a place in Indonesia that:

1. is held or can be accessed at any time;

2. is owned, rented or available to be used; and

3. is not merely a place of transit for the individual;

b. has a center of vital interests in Indonesia that is used by the individual as a

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a. Permanent Stay/Resident Permit Card (KITAP);

d. a contract or agreement to perform work, business or activities in Indonesia for

(1) An individual constituting a non-resident taxpayer is:

a. an individual who does not reside in Indonesia;

1. permanently residing in a place outside Indonesia that is not a place of

2. having a center of vital interests that shows personal, economic and/or

a) a husband or wife, children and/or next of kin residing outside

b) the income is sourced from outside Indonesia; and/or

c) being a member of a religious, educational, social and/or community

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4. becoming a resident taxpayer of another country or jurisdiction; and/or

5. other certain requirements.

(2) The requirements referred to in paragraph (1) subparagraph c number 1, number 2

a. the requirement of residing in a place outside Indonesia referred to in paragraph

d. in the event that the fulﬁlment of the requirements proceeds as referred to in

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b. at least including information regarding:

1. the name of the Indonesian Citizen;

3. validity period; and

4. name and signed or given a sign equivalent to a signature by the

c. the period referred to in subparagraph b number 3 expires no later than 6 (six)

b. having obtained a Certiﬁcate of Indonesian Citizens Fulﬁling the Requirements to

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