DIRECTOR GENERAL OF TAX REGULATION NUMBER PER-15/PJ/2025 CONCERNING THE LIMITATIONS OF CERTAIN CRITERIA FOR OTHER PARTIES AND THE APPOINTMENT OF OTHER PARTIES TO COLLECT, PAY AND REPORT INCOME TAX ON INCOME RECEIVED OR OBTAINED BY DOMESTIC TRADERS BY TRADING MECHANISMS THROUGH ELECTRONIC SYSTEMS
Amid the rapid growth of the digital economy, the government continues to strengthen the mechanisms for collection, payment, and reporting of taxes on online trade. On August 5, 2025, the Indonesian government, through the Director General of Taxes, issued Regulation of the Director General of Taxes Number 15 of 2025 (PER-15/PJ/2025) to further regulate the appointment of Other Parties as Income Tax collectors on income received by Domestic Traders through electronic trading systems in accordance with the mandate of Article 4 of Minister of Finance Regulation Number 37 of 2025.
The following are the general provisions in PER – 15/PJ/2025:
Appointment of Other Parties
The Director General of Taxes (“DJP”) appoints Other Parties as Article 22 Income Tax collectors to carry out the collection, payment, and reporting of taxes on income received or earned by Domestic Traders through the Electronic Trading System (“PMSE”) mechanism, including income received or earned by Domestic Traders from transactions conducted through PMSE Organizers with Government Agencies.
The Other Party appointed by the DJP are PMSE Organizers residing or domiciled within or outside the territory of the Republic of Indonesia who meets certain criteria. The appointment of the Other Party takes effect at the beginning of the month following the date of the DJP Decree regarding the appointment of the Other Party.
PMSE Organizers who have not been appointed as Other Parties but choose to be appointed as Other Parties can submit notification directly to the Tax Service Office (“KPP”) or through the Taxpayer Portal or other pages integrated with the DJP administration system.
Other Parties who residing or are domiciled outside or within the territory of the Republic of Indonesia who are appointed as Other Parties are given a registered Taxpayer Identification Number (“NPWP”) by issuing a registered certificate and a tax identification number card.
If an Other Party residing or domiciled outside the territory of the Republic of Indonesia does not meet certain criteria, the DJP may revoke the NPWP ex officio through research in accordance with the provisions of laws and regulations in the field of taxation.
The DJP may issue a decision regarding changes to the appointment of the Other Party either ex officio or based on the request from the Other Party in the event that there are data elements in the decision that differ from the actual situation within a maximum period of 1 (one) month after the date the request for change is received. The request for the Other Party is submitted directly to the KPP or through the Taxpayer portal or other pages integrated with the DJP administration system. In the event that the DJP issues a Decision on changes, the appointment as the Other Party that has met certain criteria remains valid.
Certain Criteria for Other Parties
Certain Criteria for Other Parties, namely PMSE Organizers who use an escrow account to hold income and meet the following thresholds:
- the transaction value using electronic service providers for transactions in Indonesia exceeds IDR 600.000.000 within 12 months or IDR 50.000.000 within 1 month; and/or
- the amount of traffic or users in Indonesia exceeds 12.000 within 12 months or 1.000 within 1 month.
If the PMSE Organizer does not meet certain criteria, the PMSE Organizer’s appointment as an Other Party may be revoked ex officio or based on notification from the Other Party by issuing a DJP Decree after conducting an investigation. Such notification may be submitted by the Other Party directly to the KPP or through the Taxpayer Portal or other pages integrated with the DJP administration system. The revocation shall take effect on the date the DJP Decree is issued.
Provisions for Collection, Payment, and Reporting of Income Tax
The provisions and procedures regarding the collection, payment and reporting of Article 22 Income Tax by Other Parties are carried out in accordance with laws and regulations in the field of taxation.
Furthermore, the Income Tax Article 22 collected by the Other Parties:
- may be credited as payment of Income Tax for the current year; or
- may be applied as part of the settlement of final Income Tax.
This applies to Domestic Traders who have provided information such as their name and NPWP or NIK registered with the DJP administration to Other Parties to be included in the proof of collection of Article 22 Income Tax. Furthermore, the proof of collection may be in the form of a billing document generated through electronic communication means or other electronic systems provided by Other Parties.
In the event that the billing document cannot yet include the name and NPWP or NIK of the Domestic Trader, as long as billing document is accompanied by a document proving that the Domestic Trader’s account in the Other Party’s electronic system contains the name and NPWP or NIK of the Domestic Trader registered with the DJP administration.
Income Tax Article 22 that has been collected must be deposited into the state treasury no later than the 15th of the following month and reported in the Unification Monthly Tax Return, and in the event of obtaining a DJP Decision regarding the revocation of appointment as Other Party, then the billing document produced or provided by the Other Party shall no longer be considered same as proof of Income Tax Article 22 collection.
The collection, payment, and reporting of Income Tax Article 22 for the year 2025 shall commence no later than 1 month after the appointment of the Other Party as a tax collector who meets certain criteria by issuing a DJP Decree.
For Tax Service Assistance, please contact:
Rani Widianti
T. (+6221) 2222-0200
Alvina Oktavia
T. (+6221) 2222-0200
E. alvina.oktavia@shinewing.id
