SW Indonesia Tax Update PER 19 Tahun 2025 (English)

DIRECTOR GENERAL OF TAX REGULATION NUMBER PER – 19/PJ/2025 CONCERNING THE DEACTIVATION OF TAX INVOICE ISSUANCE ACCESS FOR TAXABLE ENTERPRISES THAT FAIL TO FULFILL THEIR OBLIGATIONS IN ACCORDANCE WITH THE LAWS

The purpose of this regulation to deactivate the access for tax invoice issuance, as stipulated in the Minister of Finance Regulation Number 81 of 2024 concerning Tax Provisions in the context of the implementation of the Coretax Administration System, as amended several times, most recently by the Minister of Finance Regulation Number 54 of 2025 concerning the Third Amendment to the Minister of Finance Regulation Number 81 of 2024 on Tax Provisions in the context of the implementation of the Coretax administration system, is to regulate the deactivation of tax invoice issuance access for taxable enterprises that fail to fulfill their obligations under the tax laws and regulations in accordance with specific criteria.

The following are the main provisions stipulated in PER-19/PJ/2025:

1. SPECIFIC CRITERIA

• The Director General of Taxes (“DJP”) is authorized to deactivate the access for tax invoice issuance for taxable enterprises that fail to fulfill their obligations as taxpayers in accordance with the provisions of the laws and regulations in the field of taxation and in accordance with the specific criteria.
• The specific criteria include:
  • Failure to carry out the withholding or collection of any type of tax that is required to be withheld or collected as a withholding or collecting agent for a consecutive period of three (3) months;
  • Failure to submit the Annual Income Tax Return for the fiscal year that has become the taxpayer’s obligation;
  • Failure to submit the Value-Added Tax Periodic Returns that have become the taxpayer’s obligation for three (3) consecutive months;
  • Failure to submit the Value-Added Tax Periodic Returns that have become the taxpayer’s obligation for six (6) tax periods within a one (1) calendar year;
  • Failure to report withholding or collection statements for any type of tax that is required to be withheld or collected and has been issued for three (3) consecutive months; and/or
  • Having tax arrears of at least:
• IDR 250,000,000.00 (two hundred fifty million rupiah) for taxpayers registered at the Tax Office; or
• DR 1,000,000,000.00 (one billion rupiah) for taxpayers registered outside the Tax Office,

which have had a warning letter issued and excluding those that already have a valid Decree on the approval of installment payments or deferment of tax obligations.

1. SUBMISSION OF TAXPAYER CLARIFICATIONS FOR DEACTIVATED TAX INVOICES

• Taxpayers whose access to create Tax Invoices has been deactivated are permitted to submit a clarification.
• The clarification shall be carried out in accordance with the following provisions:
• To be submitted in writing by letter to the Head of the Tax Office where the Taxpayer is registered, in accordance with the sample format provided in the Attachment, which forms an integral part of this Director General Regulation;
• Shall include a minimum of:
• The number and date of the clarification letter or document;
• The purpose of the clarification letter or document, namely the Head of the Tax Office where the Taxpayer is registered;
• The identity of the Taxpayer or its management and/or person in charge;
• An explanation of the clarification; and
• A list of supporting documents for the clarification; and
• Shall be accompanied by supporting documents, at a minimum comprising:
• Evidence of tax withholding or collection for the obligation to withhold or collect taxes for each type of tax that should have been withheld or collected, consecutively for 3 (three) months;
• Receipt of submission of the Annual Income Tax Return for the relevant tax year;
• Receipt of submission of the Value Added Tax (VAT) Periodic Tax Returns for which the taxpayer is obligated, consecutively for a period of 3 (three) months;
• Receipt of submission of the Value Added Tax (VAT) Periodic Tax Returns for 6 (six) Tax Periods within 1 (one) calendar year for which the taxpayer is obligated;
• Evidence of reporting of withholding or collection for each type of tax required to be withheld or collected, consecutively for a period of 3 (three) months; and/or
• Evidence of payment of tax arrears and/or a valid Decree approving installment payments or deferment of tax obligations

1. CLARIFICATION PROVISIONS

• Based on the examination, the Head of the Tax Office shall decide to approve or reject the Taxpayer’s clarification of the clarification letter no later than 5 (five) working days after the clarification letter is submitted. In the event that the Taxpayer’s clarification is approved, the Head of the Tax Office shall reactivate the Taxpayer’s access to issue Tax Invoices.
• The Head of the Tax Office:
• Approve the Taxpayer’s clarification in the Taxpayer has fulfilled the tax obligations that were the basis for the deactivation of access to issue Tax Invoices; or
• Reject the Taxpayer’s clarification in the Taxpayer has not fulfilled the tax obligations that served as the basis for the deactivation of access to issue Tax Invoices.
• In the event that the examination period has elapsed and the Head of the Tax Office has not rendered a decision to approve or reject the Taxpayer’s clarification, the clarification shall be acted upon by reactivating the Taxpayer’s access to issue Tax Invoices. If the Taxpayer continues to meet the criteria for deactivation within 5 (five) working days following the reactivation, the Head of the Tax Office shall deactivate the access to issue Tax Invoices again.

1. PROVISIONS FOR REACTIVATION

• The reactivation of access to issue Tax Invoices under this Director General Regulation shall be implemented provided that the Taxpayer’s access has not been deactivated in accordance with the Director General of Taxes Regulation concerning the deactivation of access to issue Tax Invoices in connection with addressing the issuance and/or use of invalid Tax Invoices.

This regulation was established on October 22, 2025.

For Tax Service Assistance, please contact:

            Rani Widianti

            T. (+6221) 2222-0200

            E. rani.widianti@shinewing.id

            Alvina Oktavia

            T. (+6221) 2222-0200

            E. alvina.oktavia@shinewing.id