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TAX ALERT

Article 22 Income Tax Object

On 25 July 2025, the Minister of Finance (MoF) issued Regulation No. 51/2025 regarding the Article 22 Income Tax Object. This regulation provides implementing guideline with respect to Article 22 Income Tax Object:

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Marketplace as Article 22 Income Tax Collector for Ecommerce Trading Transaction

On 11 June 2025, the Minister of Finance (MoF) issued Regulation No. 37/2025 concerning the appointment of Marketplaces as Article 22 Income Tax Collectors for e-commerce transactions. This regulation establishes the mechanisms for tax withholding, payment, and reporting of income earned by local traders through e-commerce platforms.

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Tax Audit

On 10 February 2025, the Minister of Finance issued Regulation No. PMK-15/2025 regarding the “Tax Audit”, with the main changes are as follows:

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Provision of Other Value as Tax Base and Certain Amount of VAT

On 4 February 2025, the Minister of Finance issued Regulation No. PMK-11/2025 regarding the “Provisions of Other Value as Tax Base and Certain Amount of Value Added Tax”, to amend several tax regulations with highlight of the amendment as follows:

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Income Tax Article 21 borne by Government on Certain Income

On 4 February 2025, the Minister of Finance issued Regulation No. PMK-10/2025 regarding the “Income Tax Article 21 borne by Government on Certain Income for Economic Stimulus Fiscal Year 2025”, with the highlight of the regulation as follows:

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Procedures for Correction Objection, Reductions, Elimination, and Cancellation in Taxation Sector

On 23 December 2024, the Minister of Finance issued Regulation No. PMK-118/2024 regarding the “Procedures for Corrections, Objections, Reductions, Eliminations and Cancellations within the Taxation Sector”. This regulation which effective from 1 January 2025, contains 4 (four) points as follows:

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VAT Rate for Delivery of Goods and Services for January 2025 Onwards

On 31 December 2024, the Minister of Finance issued Regulation No. PMK-131/2024 regarding the “Value Added Tax Treatment on Import of Taxable Goods, Delivery of Taxable Goods, Delivery of Taxable Services, Utilization of Intangible Taxable Goods from Outside the Customs Area within the Customs Area, and Utilization of Taxable Services from Outside the Customs Area within the Customs Area.” This regulation aims to implement the 12% VAT Rate as mandated by Article 7 paragraph (1) letter b, effective from 1 January 2025. The summary of the regulation is as follows:

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12% VAT Increase – Economic Stimulus Illustration of VAT Objects

On 16 December 2024, the Government announced that the VAT rate will increase to 12% effective from 1 January 2025. As part of this policy, the Government has also introduced several economic stimulus measures to enhance societal welfare, as detailed below:

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Income Tax Treatment on Benefit in Kind (PMK 66/2023)

On 27 June 2023, the Ministry of Finance issued MoF Regulation No. 66/2023 regarding “Income Tax Treatment on Benefit In Kind” as mandated in Article 31 Government Regulation No. 55/2022. Effective since 1 July 2023, this regulation revokes and replaces MoF Regulation No. PMK-167/PMK.03/2018 regarding the “Provision of Meals and Drinks for All Employees and Benefits in Kind on Certain Region Deductible from Employer Gross Income”. The summary of the regulation are as follows:

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Implementation Regulation of General Tax Provisions and Procedures Law (PP 50/2022)

On 12 December 2022, the Government of Indonesia issued Government Regulation No. PP 50/2022 as an Implementation Regulation of General Tax Provisions and Procedures (KUP) Law as last amended under the Harmonization of Tax Regulation.

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VAT Law Implementation (PP 44/2022)

On 2 December 2022, the Government of the Republic of Indonesia has issued Government Regulation Number 44 of 2022 (PP 44/2022) regarding Implementation of Value Added Tax (VAT) on Goods and Services and Luxury Goods sales tax (LST).

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Interest rates for calculation of administrative sanction for December 2022

On 29 November 2022, the Ministry of Finance issued Decree No. KMK-63/KM.10/2022 regarding Interest Rates as The Basis for Calculation of Administrative Sanctions in The Form of Interest and Interest Reward for 1 December to 31 December 2022 period. Kindly find enclosed the comparison with the previous period (1-30 November 2022) as detailed below:

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KITE Exemption – Regulation Update

On 27 October 2022, the Ministry of Finance issued Regulation PMK-149/PMK.04/2022 regarding exemption of Import Duty and not-collected Value-Added Tax (VAT)/Luxury Goods Sales Tax on the import of goods and materials to be processed, assembled, or installed on other goods for export purposes (KITE Pembebasan).

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DGT Regulation on VAT Invoice

On 31 March 2022, the Directorate General of Tax issued DGT Regulation No. PER-03/PJ/2022 regarding VAT Invoice.

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Harmonisation of Tax Regulations

On 29 October 2021, the Government of Indonesia issued Law No.7/2021 regarding Harmonisasi Peraturan Perpajakan (HPP) / Harmonization of Tax Regulations. This new law replaces and updates stipulations previously governed under Ketentuan Umum Perpajakan (KUP) Law, Income Tax Law, Value Added Tax Law, and Excise Law. This new law also adds new stipulations on Program Pengungkapan Sukarela / Voluntary Disclosure Program and Carbon Tax.

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Taxation on Sales of Phone Credit and SIM Card

On 1 September 2021, the Director General of Tax (DGT) issued Regulation No PER-18/PJ/2021 regarding collection of Value Added Tax (VAT) and Withholding Tax (WHT) on sales of phone credit and SIM card.

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New Indonesia – Singapore Double Taxation Agreement (DTA)

On 31 May 2021, the Directorate General of Tax issued On 11 May 2021, the President of Indonesia has issued President Regulation No.35/2021 that ratifies the new DTA between Indonesia and Singapore that was signed on 4 February 2020. The Tax Treaty will be effective on 1 January 2022 as per Article 29 of the new DTA.

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Implementation Instruction on Review of Certificate of Domicile (COD) of Non-Resident Taxpayer in Tax Audit, Tax Objection, and Reduction or Cancellation of Tax Assessment Letter

On 31 May 2021, the Directorate General of Tax issued Circular Letter No. SE-35/PJ/2021 regarding Implementation Instruction on Review of COD of Non-Resident Taxpayer in Tax Audit, Tax Objection, and Reduction or Cancellation of Tax Assessment Letter. The regulation was issued to address the lack of clear procedural guideline in the review of COD during a Tax Dispute process and to provide legal certainty to
the disputing parties.

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Extension and Expansion of Covid-19 Tax Incentive

On 1 February 2021, the Ministry of Finance issued Regulation No PMK-9/PMK.03/2021. This regulation extends the period and expands the industry coverage of the Covid-19 Tax Incentive previously stipulated under MoF Regulation No. PMK-44/PMK.03/2020 as last amended by PMK-110/PMK.03/2020.

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Corporate Income Tax Deduction Facility (Tax Holiday Incentive)

On 24 September 2020, the Ministry of Finance has issued Regulation No. PMK-130/PMK.010/2020 regarding Corporate Income Tax Deduction Facility (Tax Holiday Incentive). The regulation provides an update on administrative, procedural and eligibility for taxpayers that wish to apply if their industry is not listed as a “Pioneer Industry”.

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Criterion of Religious Services not subject to VAT

On 23 July 2020, the Ministry of Finance issued Regulation No PMK-92/PMK.03/2020 regarding Criterion of Religious Services Not Subject to VAT. Effective since 22 August 2020, the regulation provides the implementation basis on the VAT exclusion on religious service.

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Aid or Donations and Grants Not Subject to Income Tax

On 21 July 2020, the Ministry of Finance has issued Regulation No. PMK-90/PMK.03/2020 on aid or donations and grants not subject to Income Tax.

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Expanded Scope of Covid-19 Tax Incentive

On 14 August 2020, the Ministry of Finance issued Regulation No PMK-110/PMK.03/2020. This regulation updates the Covid-19 Tax Incentive previously stipulated under MoF Regulation No. PMK44/PMK.03/2020 as last amended by PMK-86/PMK.03/2020.

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E-Objection

On 29 July 2020, the Directorate General of Tax issued PER-14/PJ/2020 regarding Procedures on Tax Objection Electronic Filing (e-Objection). This regulation was issued as a follow-up on Article 9 of MoF Regulation No PMK-9/PMK.03/2013 as last amended by PMK-202/PMK.03/2015.

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Other Value as VAT Imposition Base for Certain Agricultural Products

On 27 July 2020, the Minister of Finance issued Regulation No. PMK-89/PMK.010/2020 regarding “Other Value” as Value Added Tax Imposition Base for Certain Agricultural Products. 

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VAT Centralization Implementation

On 25 June 2020, the Directorate General of Tax issued PER-11/PJ/2020 regarding Determination of One Location or More as VAT Centralization Location. Effective since 1 July 2020, this regulation revokes the DGT Regulation PER 19/PJ/2010 and updates some of the prevailing VAT Centralization regulations.

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