Indonesia tackles tax data infrastructure issues in latest legislative updates

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Indonesia tackles tax data infrastructure issues in latest legislative updates

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Dewa Nugraha and Julius Wahyu Daryono of GNV Consulting summarise new tax data reporting rules, guidance on the taxation of domestic dividends, and transitional relief related to the Coretax system

Minister of Finance Regulation No. 8 of 2026

The Indonesian Ministry of Finance (MOF) has officially released Regulation No. 8 of 2026. The regulation updates the previous framework (MOF Regulation No. 228/PMK.03/2017) to strengthen the national tax data infrastructure and provide legal certainty for government agencies, institutions, and associations.

The government identified that the previous regulation did not adequately address feedback mechanisms for data usage or procedures for gathering additional data when initial submissions were insufficient. MOF Regulation No. 8/2026 was introduced to ensure legal certainty and to align data requirements with the current operational needs of the Directorate General of Taxes (DGT).

Key regulatory updates

The new regulation introduces several critical shifts in the tax reporting framework.

  • Mandatory data submission – government agencies, institutions, and associations are required to provide tax-related data to the DGT.

  • DGT notification – the DGT will now provide a formal notification to the submitting parties regarding the data that has been provided.

  • Enhanced transparency (new Article 5A) – for the first time, the DGT is required to issue a formal data and information utilisation notification to report how the submitted data has been used.

  • Authority to collect additional data (new Article 5B) – if the data received is insufficient, the DGT is authorised to collect additional information regarding a taxpayer's obligations:

    • Data scope – requests may include information describing business activities, turnover, income, or wealth;

    • Compliance – parties receiving a request must provide data that reflects the actual situation;

    • Deadline – data must be submitted within one month of receiving the request; and

    • Method – submission can be completed online or directly to the DGT.

  • Delegation of authority (new Article 5C) – the director general of taxes may delegate the authority to notify usage and collect data to senior tax data policy officials or to the heads of regional tax offices.

Effective date

The regulation was enacted on February 11 2026 and officially came into force on its promulgation date, February 27 2026.

Internal Memo No. ND-1/PJ/PJ.02/2026

The DGT has issued Internal Memo No. ND-1/PJ/PJ.02/2026 (ND-1/2026) to clarify the taxation of domestic dividends. This move tightens supervision over dividends distributed without a formal general meeting of shareholders (GMS).

This is a critical reminder for businesses that procedural compliance is mandatory to benefit from the dividend tax exemption facility.

Policy transformation: what has changed?

Previously, many businesses assumed that all dividend distributions were automatically tax-exempt. The following table highlights the key changes.

Aspect

Previous practice/common perception

New clarification (ND-1/2026)

Formal requirements

Often considered flexible as long as funds were distributed to shareholders.

Mandatory via a GMS, interim dividends, or other valid circular resolutions.

Tax exemption status

Applied broadly without strict procedural audits.

A non-GMS/non-interim dividend fails to meet the exemption criteria and remains taxable.

Use of a tax exemption certificate for non-GMS/non-interim dividends

Often used to waive withholding tax on all dividend types.

Individuals – the tax exemption certificate is invalid (10% final tax still applies).

Corporations – tax exemption applies (no 15% withholding tax), but the non-GMS/non-interim dividend must be reported as income in the corporate income tax return.

Procedural formality: the key to tax exemption

ND-1/2026 emphasises that a tax exemption only applies if the distribution follows corporate legal standards, including:

  • A valid GMS;

  • Interim dividends in accordance with the company’s articles of association; and

  • Circular resolutions signed by all shareholders with voting rights.

Tax consequences and ‘hidden dividends’

If the distribution occurs outside these formal channels, the payer must withhold tax as follows:

  • Domestic individual taxpayers – subject to a 10% final tax;

  • Domestic corporate taxpayers/permanent establishments – subject to 15% withholding tax (Article 23); and

  • Foreign taxpayers – subject to 20% withholding tax (Article 26) or applicable tax treaty rates.

The DGT also warns against ‘hidden dividends’ (e.g., company expenses for personal shareholder interests or excessive loan interest), which will be reclassified and taxed as dividends.

Effective date

Issued on February 3 2026, this note is marked as ‘immediate’ and serves as a direct guideline for tax offices to monitor compliance in the field.

DGT Announcement No. PENG-21/PJ.09/2026

The DGT has issued Announcement No. PENG-21/PJ.09/2026 (PENG-21/2026), which provides significant relief for taxpayers during the transition to the new Coretax system.

What has changed? (normal rules v relaxation)

The policy offers a temporary departure from standard procedures to support taxpayers during the system modernisation process.

Aspect

Normal rules

Relaxation policy (PENG-21/2026)

Filing deadline

Due on January 20 2026

Extended until February 28 2026

Administrative sanctions

Subject to late filing fines

Waived if filed by February 28 2026

Tax bill

Issued automatically for delays

No bill issued, or cancelled automatically if already sent

Key policy highlights

The policy aims to provide legal certainty and ease of administration during the system transition. The three main points are as follows:

  • Deadline extension – the final date to file the Article 21 income tax return for the December 2025 period was moved from January 20 2026 to February 28 2026.

  • Waiver of fines – taxpayers are exempted from administrative sanction for late filing, provided the return was submitted within the new deadline.

  • Automatic cancellation – the DGT commits to not issuing a tax collection notice. If a notice has already been issued to sanction the taxpayer, the DGT regional office will cancel the sanction automatically (ex officio).

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