Insights

The new era of international taxation encourages multinational investors to place tax readiness as an integral part of investment strategy and corporate governance. In an increasingly transparent global business environment, taxation is no longer viewed merely as a compliance obligation, but also as a critical element in risk management, decision-making, and investment sustainability. This article … Read more

The implementation of the Global Minimum Tax (Pillar Two) marks a new chapter in international tax reform aimed at establishing a fairer, more transparent, and more consistent tax system for multinational enterprises. Through the adoption of the Global Anti-Base Erosion (GloBE) Rules and their implementation in Indonesia under Minister of Finance Regulation (PMK) No. 136 … Read more

Minister of Finance Regulation (PMK) Number 136 of 2024 establishes the legal and technical framework for implementing the Global Minimum Tax (Pillar Two) regime in Indonesia in accordance with the Global Anti-Base Erosion (GloBE) Rules developed under the OECD/G20 Inclusive Framework. This article examines the regulation’s principal provisions, including its scope of application, the operation … Read more

The relationship between the Global Minimum Tax (Pillar Two) and Transfer Pricing Documentation has become an increasingly important aspect of international tax governance. The issuance of Indonesia’s Minister of Finance Regulation (PMK) Number 136 of 2024 on the Global Minimum Tax and PMK No. 172 of 2023 on the Application of the Arm’s Length Principle … Read more

The development of the Global Minimum Tax (Pillar Two) brings a fundamental transformation in the way multinational enterprises manage their tax strategies, shifting from a tax planning-oriented approach toward stronger tax governance characterized by greater transparency, accountability, and sustainability. The enactment of Indonesia’s Minister of Finance Regulation (PMK) No. 136 of 2024 emphasizes that tax … Read more