Indonesia: Tax amnesty implementation regulations

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Indonesia: Tax amnesty implementation regulations

Karyadi-Freddy
puspita.jpg

Freddy
Karyadi

Luna
Puspita

To implement the Tax Amnesty Law, the Indonesian government has issued various regulations, procedures and plans.

This includes regulations, such as the Implementation of Tax Amnesty Law, procedures for assets repatriation into Indonesia, the banks appointed to receive such assets, investment products in the capital market fields in relation to the tax amnesty, and examining the policy to support the implementation of the Tax Amnesty Law. In addition, the government plans to issue another regulation in relation to special purpose vehicles.

Ministry of Finance Regulation No 118/PMK.03/2016 on the Implementation of Tax Amnesty Law (MoF Regulation No. 118/2016) states the general procedure for the tax amnesty application and the calculation for redemption payment. In order to apply for tax amnesty, taxpayers must disclose their assets in a statement letter and pay the redemption payment.

In the event that taxpayers intend to repatriate assets back to Indonesia, the taxpayer would have to invest any funds relating to the repatriated assets within three years after the funds have been received by an appointed bank. The investment can be conducted through several instruments, as follows:

1) Within the financial markets, as regulated under MoF Regulation No. 123/PMK.08/2016 on the amendment of MoF Regulation No. 119/PMK.08/2016 on the Procedures for Asset Repatriation into Indonesia and Placement in Investment Instruments; or

2) Outside of the financial markets, as regulated under MoF Regulation No. 122/PMK.08/2016 on the Procedures for the Transfer of Taxpayer's Property into the Territory of the Republic of Indonesia and Placement of Foreign Investment Outside of the Financial Markets In Relation to the Tax Amnesty.

Under option 1 above, repatriated assets can be invested in the following vehicles:

  • Indonesian State Commercial Papers (Surat Berharga Negara);

  • State-owned company bonds;

  • State-owned financing company bonds;

  • Financial investment products organised by receiving banks;

  • Private company bonds that are traded under the supervision of the Financial Services Authority;

  • Investment in infrastructure projects funded through public-private partnership schemes;

  • Investment in real sector based on government priorities; and/pro

  • Other types of investment allowed by the prevailing regulations.

Under option 2 above, repatriated assets can be invested in the following vehicles:

  • Infrastructure projects through cooperation between the government and a business entity;

  • Investment in the real sector based on government priorities;

  • Investment in the form of property investment;

  • Investment in a company domiciled in Indonesia;

  • Investment in the form of bar gold; and/or

  • Other types of investment allowed by the prevailing regulations.

To support the tax amnesty scheme, the Directorate General of Tax has issued Instruction No. INS-03/PJ/2016 on the Examination Policy to Support the Implementation of the Tax Amnesty Law, which stipulates that tax officials will not issue any investigation or warrant a new audit unless for the examination of over payments of tax, or matters relating to the services provided to the taxpayer.

Separately, the government has reduced the income tax for the transfer of real property from 5% to 2.5%. President Joko Widodo also unveiled plans to decrease the corporate income tax from 25% to 17%.

Freddy Karyadi (fkaryadi@abnrlaw.com) and Luna Puspita (lpuspita@abnrlaw.com), Jakarta

Ali Budiardjo, Nugroho, Reksodiputro, Law Offices

Tel: +62 21 250 5125

Website: www.abnrlaw.com

more across site & shared bottom lb ros

More from across our site

While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
Gift this article