SW Indonesia Tax Update PMK 15 2025 – ENG

REGULATION OF THE MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA NUMBER 15 OF 2025 (PMK 15/2025) REGARDING TAX AUDIT

This regulation is designed to provide legal clarity on tax audits, including audits for land and building taxes.

A tax audit involves gathering and processing data, information, and evidence in an objective and professional manner, following specific audit standards. The purpose is to check whether tax obligations are being met and to support other purposes in line with the laws and regulations in the field of taxation.

The Director General of Taxes is authorized to conduct audits aimed at testing compliance with tax obligations. These audits consist of:

1. Comprehensive Audit: An audit to assess compliance with tax obligations, covering all items in the Tax Return and/or the Tax Object Notification Letter in depth. The maximum duration for this audit is 5 (five) months, starting from the date the Tax Audit Notification Letter is issued.
2. Focused Audit: An audit to assess compliance with tax obligations, focusing on one or more items in the Tax Return and/or the Tax Object Notification Letter in depth. The maximum duration for this audit is 3 (three) months, starting from the date the Tax Audit Notification Letter is issued.
3. Specific Audit: An audit to assess compliance with tax obligations, conducted specifically on one or more items in the Tax Return and/or the Tax Object Notification letter, data, or certain tax obligations in a simplified manner. The maximum duration for this audit is 1 (one) month, starting from the date the Tax Audit Notification Letter is issued.

Furthermore, the Director General of Taxes is authorized to conduct audits for other purposes in order to implement the provisions of laws and regulations in the field of taxation. This audit can involve determining, matching, or ensuring compliance with legal obligations, or gathering materials related to the purpose of the audit. The maximum duration for a tax audit is 4 (four) months, starting from the date the Tax Audit Notification Letter is issued.

The duration of the above audits may be extended for a maximum period of 4 (four) months if it is related to:

1. Taxpayers within the same group;
2. Taxpayers who are suspected of engaging in transfer pricing transactions and/or other special transactions that indicate financial transaction manipulation.

The duration for the Closing Conference of Audit Results and reporting, as referred to in paragraph (1) letter b, is a maximum of 30 (thirty) working days, starting from the date the Notification of Tax Audit Findings is issued.

In the implementation of the audit, the Tax Auditor may borrow or request data by sending a data request letter, such as:

1. Books, records, and/or documents that serve as the basis for bookkeeping or record-keeping, and other documents related to the income earned, business activities, independent work of the taxpayer, or tax objects, including electronic data, in the case of an audit to test compliance with tax obligations; or
2. Books, records, and/or documents, including electronic data, related to the purpose of the audit in the case of an audit for other purposes in order to implement the provisions of laws and regulations in the field of taxation.

The taxpayer is required to fulfill the data request within a maximum of 1 (one) month from the date the request letter is issued. If the books, records, and/or documents, including electronic data, that are borrowed or requested in the letter are provided by the taxpayer after this period, they will be considered not provided during the audit.

If the books, records, and/or documents, including electronic data, that are borrowed or requested have not been provided, either fully or partially, and the 1 (one) month period has not yet passed, the Tax Auditor may issue a written warning up to 2 (two) times, as follows:

1. The first warning letter will be issued 2 (two) weeks after the date of delivery of the request letter; and
2. The second warning letter will be issued 3 (three) weeks after the date of delivery of the request letter.

If the audit is conducted to assess compliance with tax obligations, the Tax Auditor will initiate a Preliminary Findings Discussion by issuing a notice to the taxpayer, accompanied by a list of preliminary findings. The Preliminary Findings Discussion must be conducted no later than 1 (one) month prior the audit period expires.

The taxpayer is required to provide a written response to the Notification of Tax Audit Findings and the list of audit findings within a maximum of 5 (five) working days from the date of receipt of the Notification of Tax Audit Findings.

A request for a discussion with the Quality Assurance Team for the audit may be made, under the following conditions:

1. The taxpayer, representative, or taxpayer’s attorney submits a response to the Notification of Tax Audit Findings, indicating partial agreement with the audit findings or disagreement with the entire audit results, or fails to provide a written response within the specified period;
2. The taxpayer, representative, or taxpayer’s attorney attends the Final Discussion of Audit Results;
3. The taxpayer, representative, or taxpayer’s attorney expresses their intention to request a discussion with the Quality Assurance Team, as recorded by the Tax Auditor in the minutes of discussion of tax audits;
4. The minutes of discussion of tax audits have been signed by both the Tax Auditor team and the taxpayer, representative, or proxy of the audited taxpayer;

• The minutes of the final discussion of Audit Results and the summary of the closing conference have not been signed by the taxpayer, representative, or proxy of the audited taxpayer; and
• There is a difference of opinion in the discussion minutes that is limited to the legal basis for corrections between the taxpayer and the Tax Auditor during the Closing Conference of Audit Results.

The request letter for a discussion with the Quality Assurance Team for the audit must be submitted within a maximum of 3 (three) working days from the date of signing the minutes of discussion of tax audits and copied to the Officials in the Audit Implementation Unit.

At the time this Ministerial Regulation comes into effect:

1. Audits of taxes other than Land and Building Tax that began prior this Ministerial Regulation came into effect and are not yet completed, will be resolved based on the Minister of Finance Regulation No. 17/PMK.03/2013, as amended several times, with the last amendment being the Minister of Finance Regulation No. 18/PMK.03/2021;
2. Audits of Land and Building Tax that began prior this Ministerial Regulation came into effect and are not yet completed, will be resolved based on the Minister of Finance Regulation No. 256/PMK.03/2014; and
3. Audit administration that began prior this Ministerial Regulation came into effect and is not yet completed will be carried out according to the provisions set out in Article 2, paragraph (3) of this Ministerial Regulation.

This Ministerial Regulation shall come into effect on the date of promulgation, February 14^th, 2025.

For tax service assitance, please contact:

            Rani Widianti

            T. (+6221) 2222-0200

            E. [email protected]

            Alvina Oktavia

            T. (+6221) 2222-0200

            E. [email protected]