Indonesia introduces three business-friendly tax changes

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 introduces three business-friendly tax changes

Sponsored by

GNV Green BG.png
Tax changes

Aditya Wicaksono and I Dewa Made Agung Nugraha of GNV Consulting Indonesia look at three recent tax law amendments that impact withholding tax, deductions for human resource investment and income tax for certain taxpayers.

On September 5 2019, the Government of Indonesia’s Directorate General of Taxes (DGT) issued DGT Decree KEP-599/PJ/2019 (KEP-599). This new decree relates to Article 23/26 under DGT Regulation PER-04/PJ/2019 and obliges income tax withholders to prepare withholding slips and submit monthly Article 23/26 withholding tax (WHT) returns.

KEP-599 stipulates that taxpayers that meet certain criteria and are registered under certain tax offices must prepare withholding slips and submit monthly Article 23/26 WHT returns in accordance with DGT Regulation PER-04/PJ/2019. Companies should check the attachment to KEP-599 to confirm whether or not they meet these criteria.

These requirements will still apply even if a taxpayer’s registered tax office has changed. If a taxpayer’s status as a VAT-able company (pengusaha kena pajak - PKP) is revoked, it should follow the requirements set out under DGT Regulation PER-53/PJ/2009 instead of DGT Regulation PER-04/PJ/2019.


At the same time (September 6), the Ministry of Finance (MoF) issued MoF Regulation 128/PMK.010/2019 (PMK-128). This new regulation contains provisions for the reduction of gross income on professional placements, internships and/or learning activities in the context of mentoring and the development of human resources in certain competencies.

PMK-128 provides that the reduction of gross income can be as high as 200% of total expenses incurred for professional placements, internships and/or learning activities, provided the requirements and competency criteria are satisfied. The regulation lists the types of deductible expenses and criteria for obtaining the additional gross income reduction, and includes example calculations.

To enjoy the facility, a taxpayer is required to submit a notification through the OSS system. The effectiveness of such programmes will be evaluated by the related ministry or local government office. If the programme is considered ineffective, the facility will not be provided in the subsequent fiscal years. PMK-128 came into effect on September 9 2019.


Most recently, on September 24 2019, the DGT issued Circular SE-25/PJ/2019 (SE-25). This latest circular provides a guideline for calculating the amount of Article 25 income tax instalments in the current fiscal year for taxpayers that are required to prepare periodic financial statements; these taxpayers include new taxpayers, banks, state-owned and local government-owned enterprises, public companies and certain individual entrepreneurs.

SE-25 introduced several changes that affect the amount of Article 25 instalments that certain taxpayers with periodic financial statement obligations must pay. This impacts any taxpayer that: has carried forward a fiscal tax loss; is a public company benefiting from the tariff reduction facility; obtains the net income reduction facility; and that obtains the 50% tariff reduction facility.

The circular also provided confirmation of the definition of ‘net fiscal profit’ for the above-mentioned companies. It confirmed the Article 25 instalment for the current tax year for taxpayers that no longer meet the criteria of taxpayers, as referred to in Government Regulation 23 of 2018, (final tax for taxpayers with certain maximum revenue). It also provided a calculation of Article 25 instalments for certain individual entrepreneurs.

SE-25 provided explanations regarding the overbooking procedures for Article 25 instalment overpayment. It explained the Article 25 Instalment obligation which is calculated based on MoF Regulation 215 215/PMK.03/2018, which is effective starting from the fiscal period January 2019. The final aspect is that during the transition period of January 2019 to March 2019, any administrative penalty incurred due to the incorrect calculation of Article 25 instalment is nullified by an official assessment, as it is considered to be not the taxpayer’s mistake.

more across site & shared bottom lb ros

More from across our site

Governments are rewriting tax policy for the AI era, deploying digital taxes, tailored incentives and algorithmic enforcement that redefine where value is created
Wingrove will succeed Bill Thomas, who has served in the role since 2017; in other news, Andersen unveiled a sharp increase in revenues for 2025
Partners are divided on Italy vs PDM D’s analytical depth, evidentiary standards, and what the judgment signals for future intra-group financing cases
As GCCs increasingly become strategic hubs, multinationals face heightened risks around permanent establishment and place of effective management
While all options presented ‘drawbacks’, European Commission tax leader Wopke Hoekstra said the controversial US carve-out deal has ‘many benefits’
From tech preparations to competitiveness concerns, Tax Systems’ Russell Gammon addresses the most pressing client considerations arising from the SbS deal
Despite estimates that the US/OECD agreement will cost countries billions, the Fair Tax Foundation’s Paul Monaghan believes the deal is a ‘necessary evil’
The firm’s eye-catching UK launch is a major statement of intent, but it will face stern opposition in its quest to be the top global tax player
The postponement came after industry representatives flagged implementation issues with the registration regime; in other news, firms made key tax partner additions
Despite the increased yield, the time taken to resolve enquiries was at a six-year high, new HMRC statistics have revealed
Gift this article