The Directorate General of Taxes (DJP) issued PER-11/PJ/2025 on May 2025 concerning the provisions for reporting Income Tax, Value Added Tax, Sales Tax on Luxury Goods, and Stamp Duty in the context of implementing the Core Tax Administration System. This regulation serves as a new guideline that provides detailed instructions on the format, filing instructions, and submission of various types of withholding tax slips, periodic tax returns (SPT Masa), and annual tax returns (SPT Tahunan), including other tax-related documents that all taxpayers must pay attention to in accordance with the newly implemented Coretax system.

PER-11/2025 is meant to operate the Minister of Finance Regulation (PMK) No. 81/2024 concerning Tax Provisions in the Context of Implementing the Core Tax Administration System.

Key Points covered in PER-11/PJ/2025:

• The format, content, and instructions for filing:

1. 1. Income Tax Article 21/26 Withholding Slips
   2. Unified Income Tax (PPh Unifikasi) Withholding
   3. State Revenue Reports for Upstream Oil and Gas
   4. VAT Monthly Returns (SPT Masa PPN)
   5. Stamp Duty Monthly Returns
   6. Individual Income Tax Annual Returns (SPT Tahunan OP)
   7. Corporate Income Tax Annual Returns (SPT Tahunan Badan)
   8. Article 25 Income Tax Installment Reports

• The information and/or documents that must be attached to the Tax Return, as well as the format and means of submitting the information and/or documents;
• The procedures for submission, receipt, and processing of the Tax Return;
• The Tax Return must include at minimum the type of tax, the taxpayer’s name and ID number, the applicable tax period or year, and the signature of the taxpayer or their authorized representative.

In addition to the provisions as mentioned above, the following shall also apply:

• Individually-Owned Businesses Are Required to Withhold Income Tax (PPh)

Individuals who run a business or perform independent work are now required to withhold Income Tax (PPh) Article 23 and Income Tax Article 4 paragraph (2) on income derived from rentals, including land and building leases. The individuals mentioned above include individuals who perform independent work and/or run a business and maintain bookkeeping.

• VAT Invoices (Faktur Pajak)

The deadline to upload electronic VAT invoices (e-Faktur) by Taxable Entrepreneurs (PKP) has been extended to the 20^th of the following month (previously the 15^th).

• VAT Invoice for Retailers

Retailers who are registered as Taxable Entrepreneurs (PKP) are allowed to issue VAT invoices without the buyer’s identity, as well as without the name and signature of the authorized official. However, the invoice must still contain at least the following information:

• Seller’s identity: name, address, and Tax ID Number (NPWP);
• Transaction details: type of goods/services, quantity, selling price, compensation, and discounts;
• Tax: the amount of VAT or VAT and Luxury Goods Sales Tax (PPnBM) collected;
• Invoice number: code, serial number, and date of issuance.

The invoice code and serial number are no longer follow the Directorate General of Taxes (DJP) VAT numbering system, and they it can be determined independently by the PKP according to their business practices.

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The Minister of Finance has enacted a new regulation on tax audits through Minister of Finance Regulation (PMK) No. 15 of 2025 on Tax Audits. This regulation serves as an implementing provision of Government Regulation (PP) No. 50 of 2022 concerning Procedures for the Exercise of Rights and Fulfillment of Tax Obligations. With the issuance of PMK 15/2025, the previous regulation on tax audits—PMK No. 17 of 2013, as last amended by PMK No. 18 of 2021—is hereby revoked.

The new procedures shall apply to tax audits for which the Tax Audit Notification Letter (Surat Pemberitahuan Pemeriksaan/ “SP2”) is issued on or after 14 February 2025. Tax audits initiated through an SP2 issued prior to this date will remain subject to the provisions stipulated under the previous Minister of Finance Regulations (PMKs).

The following are the key points of changes in the provisions under the new Minister of Finance Regulation on Tax Audits:

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Implementation of Pillar Two Global Minimum Tax Effective from 1 January 2025

Indonesia has officially adopted the Global Minimum Tax (GMT) under the Minister of Finance Regulation Number 136 of 2024 (PMK-136), effective from 1 January 2025. This regulation aligns with the OECD’s Pillar Two framework on GMT.

The Global Minimum Tax applies to multinational enterprises (MNEs) with an annual turnover of at least EUR 750 million. Its primary objective is to ensure that corporate income earned within a jurisdiction is taxed at a minimum effective rate of 15%, achieved through the application of a “top-up tax.”

Implications for Indonesia

Under PMK-136, the affected entities include:

1. Indonesia-based MNEs: Indonesian-headquartered groups with subsidiaries or operations abroad.
2. Indonesia-based subsidiaries of foreign MNEs.

Key Tax Mechanisms

The regulation outlines three main top-up tax mechanisms in line with the OECD Model Rules:

• Income Inclusion Rules (IIR)
• Domestic Minimum Top-up Tax (DMTT)
• Undertaxed Payment Rule (UTPR)

Additionally, the regulation specifies a De Minimis Rule applicable to jurisdictions where:

• The average CE’s GloBE revenue is less than EUR 10 million, and
• The average CE’s GloBE net income is less than EUR 1 million, or a net loss occurs.

Filling and Compliance Requirements

The filing obligations for Ultimate Parent Entities (UPEs) and Constituent Entities (CEs) are summarized below:

The afore-mentioned filings shall be submitted at the latest 15 months to the Director General of Tax (DGT) upon the fiscal year-end. The grace period of three months is however granted for initial implementation of PMK-136.

Penalties for Non-Compliance

Late submission or payment of top-up taxes will incur administrative penalties as stipulated by prevailing domestic regulations.

The Ministry of Finance recently issued several new Minister of Finance (MOF) regulations, covering a wide range of topics critical to the field of taxation, including uncollectible receivables, joint operations, stamp duties, tax facilities, corporate income tax reductions, foreign aid VAT, and core tax administration. For those in the tax sector, understanding these regulations is essential as they contain numerous important provisions. Below is a summary of each new regulation:

Summary of New MOF Regulations 2024:

1. MOF Regulation 69 of 2024 – Corporate Income Tax Reduction
   This regulation updates the previous one, offering a corporate income tax reduction facility to eligible taxpayers. It aims to encourage investment growth by providing more competitive tax incentives.
2. MOF Regulation 74 of 2024 – Reserve for Uncollectible Receivables
   MOF Regulation 74 allows the formation of reserves for uncollectible receivables that may be deducted from gross income, benefitting companies dealing with difficult-to-collect receivables by offering potential tax savings.
3. MOF Regulation 78 of 2024 – Stamp Duty Regulations
   This regulation clarifies the provisions for implementing stamp duties, including liability and procedural requirements, to assist businesses in understanding and fulfilling their stamp duty obligations.
4. MOF Regulation 79 of 2024 – Taxation in Joint Operations
   This regulation governs the tax treatment of joint operation activities, an essential framework for entities collaborating on various projects, providing legal certainty regarding the distribution of tax obligations and rights.
5. MOF Regulation 80 of 2024 – VAT and Income Tax Facilities for Foreign-Aided Projects
   This regulation provides VAT, PPnBM, and income tax facilities for government projects funded by foreign grants or loans, thereby reducing tax burdens and enhancing project funding efficiency.
6. MOF Regulation 81 of 2024 – Core Tax Administration System
   Addressing tax administration within a more integrated core tax system, MOF Regulation 81 aims to optimize Indonesia’s core tax operations, creating a more efficient and modernized tax administration system.

We are excited to share that WTS Indonesia has made significant strides in the ITR World Tax Rank 2025, further solidifying our position as a leading tax advisory firm:

• General Corporate Tax: We are pleased to announce our promotion to Tier 3, a substantial improvement from our previous status as an “Other Notable Firm.” This elevation underscores our relentless pursuit of excellence and our ability to deliver high-quality corporate tax services that align with the needs of our clients and the expectations of the industry.
• Transfer Pricing: Our consistent performance and expertise in transfer pricing have allowed us to retain our Tier 3 position. This achievement reflects our deep understanding of transfer pricing complexities and our commitment to providing reliable, top-tier advisory services that help our clients navigate intricate pricing regulations and compliance requirements.
• Tax Controversy: We are proud to be newly recognized as an “Other Notable Firm” in the tax controversy category. This new recognition marks a significant milestone for WTS Indonesia, highlighting our growing proficiency and influence in managing and resolving complex tax disputes. Our approach to tax controversy is rooted in a thorough understanding of Indonesian and international tax laws, ensuring that we offer the best possible outcomes for our clients.

These recognitions are a testament to our unwavering dedication to maintaining the highest standards of service and our continuous efforts to expand our influence and expertise in the global tax consultancy landscape.

About WTS Indonesia: Founded in 2019 by Tomy Harsono, WTS Indonesia is a leading Indonesian professional services firm specializing in tax advisory. With a team of experienced professionals, we offer comprehensive tax services designed to navigate the complexities of Indonesia’s tax system effectively. As a member of WTS Global, WTS Indonesia is part of an extensive network of tax practices that spans over 100 countries, providing our clients with both local expertise and global reach. This affiliation allows us to deliver tailored tax solutions that meet the diverse needs of businesses operating in a globalized economy.

At WTS Indonesia, we are committed to staying at the forefront of the tax industry, continuously enhancing our capabilities and expanding our service offerings to better serve our clients. For more information, visit wtsindonesia.com.