Enhanced Compliance Oversight with Financial Data Access and VAT Collection for Digital Sales

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Enhanced Compliance Oversight with Financial Data Access and VAT Collection for Digital Sales

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Indonesia is implementing a series of significant tax reforms designed to strengthen the country's tax administration, improve taxpayer compliance, and capture revenue from the rapidly growing digital economy.

Indonesia is implementing a series of significant tax reforms designed to strengthen the country's tax administration, improve taxpayer compliance, and capture revenue from the rapidly growing digital economy. Three recent regulatory developments, all issued in July 2026, represent a coordinated effort by the Indonesian Directorate General of Taxes (DGT) to modernize tax collection, expand data access, and enhance supervisory capabilities.

This article consolidates these interconnected reforms, exploring how they collectively reshape the compliance landscape for businesses operating in or engaging with the Indonesian market.

1. Enhanced Compliance Supervision

On 15 July 2026, the DGT issued Circular Letter No. SE-8/PJ/2026 on Guidelines for the Supervision of Taxpayer Compliance (the Circular Letter). This document serves as an internal implementation guideline for the DGT in carrying out taxpayer compliance supervision under Minister of Finance Regulation No. 111 of 2025. The Circular Letter revokes and replaces four previous circular letters, consolidating and updating procedures for (i) Tax extensification, (ii) Field data collection and data quality assurance, (iii) Taxpayer compliance supervision, and (iv) Follow-up of concrete data.

What's Changed?

  • The Circular Letter introduces three levels of material compliance supervision:

  • Comprehensive – a broad assessment covering all types of taxes applicable to a taxpayer for fiscal years preceding the current fiscal year. The review may include, among other things, an analysis of the taxpayer’s business processes, financial statements, and transfer pricing arrangements.

  • Simplified – an assessment covering some or all types of taxes applicable to a specified taxpayer or category of taxpayers. This review may involve an analysis of business processes and/or financial statements and may be conducted in respect of the current fiscal year and/or prior fiscal years.

  • Automated – a limited assessment covering one or more types of taxes and one or more tax periods, generally conducted through an automated review mechanism.

  • Wider supervision scope: Tax authorities now actively hunt for unregistered taxpayers and monitor entire business areas. Supervision may further involve cooperation and information exchange with other parties, provided that such activities are conducted in accordance with applicable law.

  • More data sources: the DGT may conduct supervision through various methods, including site visits, media monitoring, remote sensing, and cooperation with local authorities.


2. Financial Information Access

On 16 July 2026, the DGT issued Circular Letter No. SE-9/PJ/2026 on Procedures for Requesting Information and/or Evidence or Explanations in connection with Access to Financial Information for Tax Purposes (SE-9/PJ/2026). This implements Minister of Finance Regulation No. 108 of 2025. SE-9/PJ/2026 lets the DGT request financial information from (i) Banks, (ii) Insurance companies, (iii) Securities companies and other financial services institutions, and (v) Crypto-asset service providers that qualify as reporting entites.

Key Points

  • Access to Financial Information of Taxpayer-Related Parties – In addition to information relating directly to a taxpayer, the DGT can request data on taxpayer’s shareholder, management team, family members, beneficial owners, or any related party.

  • Two ways to get data:

  • Automatic periodic reporting (already happening)

  • Specific requests for targeted information.

  • Information that can be requested includes the identity of the account holder, the account number and any sub-account, the type of account, the account opening and/or closing date, the account balance or value, transaction records, and the location of the relevant transactions.


3. New VAT Collection on Digital Transactions

On 14 July 2026, the Minister of Finance issued Regulation No. 49 of 2026 on Procedures for the Collection of Value-Added Tax on Cross-Border Digital Transactions through the Cross-Border Digital Transaction Tax Collection System (SPP-TDLN). This regulation, i.e., MOF Regulation No. 49/2026, implements Presidential Regulation No. 68 of 2025.

How It Works

In practical terms, MOF Regulation No. 49/2026 introduces a mechanism under which Value-Added Tax (VAT) on certain purchases of digital products and services from overseas suppliers may be collected through the payment channel. This means that the Government may involve banks or non-bank payment institutions in collecting VAT when they facilitate payments for cross-border digital transactions.

What's Covered?

The use in Indonesia territory of:

  1. intangible taxable goods from outside the Indonesian customs territory in the form of digital goods; digital goods include software, apps, e-books, multimedia content, digital databases; and/or

  2. taxable services from outside the Indonesian customs territory in the form of digital services; digital services include cloud services, streaming, online platforms, automated digital services, SaaS, PaaS, IaaS.

VAT becomes payable when the SPP-TDLN Operator confirms to the Other Party that a particular cross-border digital transaction is subject to VAT. The Other Party is required to collect VAT when that confirmation is issued.

VAT Calculation Formula

VAT = 11/111 × total payment (including VAT)

The collection, payment and reporting of VAT under this mechanism are carried out through the SPP-TDLN, which is operated by a designated legal entity acting as the SPP-TDLN Operator. For purposes of the SPP-TDLN, a party that may be appointed as Other Parties who ara mandated to collect the VAT on the cross-border ditigal transactions are “Issuers” (Penerbit), consisting of banks or non-bank institutions that provide services facilitating payments for cross-border digital transactions undertaken by users of digital goods or services.

CONCLUSION: A COORDINATED APPROACH TO TAX ADMINISTRATION

Taken together, these three regulations signal a clear shift: the Indonesian DGT is moving from a reactive, paper-based tax administration to a proactive, data-driven enforcement agency. To avoid being subject to the scrutiny of the DGT, a taxpayer must among others (i) conduct a self-audit to ensure that the tax filings match the supporting documents and (ii) maintain clear record of underlying documetns for transactions.


For Further Information, Please Contact:

MetaLAW, Legal Consultant, Jakarta, Indonesia

general@metalaw.id

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