The Director General of Taxes Regulation regarding the Global Minimum Tax (Global Anti-Base Erosion Rules/GloBE) is an implementation of the OECD/G20 Inclusive Framework on BEPS agreement to ensure that multinational enterprise groups (MNE Groups) are subject to a global minimum tax. This regulation governs various aspects, ranging from the determination of GloBE taxpayer status, reporting, payment of top-up tax, to supervision mechanisms and the exchange of information among countries/jurisdictions.
Scope of GloBE
GloBE covers provisions on the imposition of top-up tax consisting of several main instruments, namely:
- Income Inclusion Rules (IIR), which are provisions that impose top-up tax on a domestic taxpayer that is a Parent Entity where another Constituent Entity of the MNE Group, directly or indirectly owned by the Parent Entity, is subject to tax at an Effective Tax Rate lower than the minimum rate in the country or jurisdiction where such other Constituent Entity conducts its business activities.
- Undertaxed Payment Rules (UTPR), which are provisions that impose top-up tax where the IIR provisions are not applied and/or the top-up tax has not been fully imposed on a domestic taxpayer that is a Constituent Entity of an MNE Group, where another Constituent Entity of the MNE Group is subject to tax at an Effective Tax Rate lower than the Minimum Rate in the country or jurisdiction where such other Constituent Entity conducts its business activities.
- Domestic Minimum Top-up Tax (DMTT), which are provisions that impose top-up tax on a domestic taxpayer that is a Constituent Entity of an MNE Group and has an Effective Tax Rate lower than the Minimum Rate.
These three instruments are intended to ensure that MNE Groups with consolidated revenue of at least EUR 750,000,000 (seven hundred and fifty million Euros) continue to pay a minimum effective tax rate of 15% in each jurisdiction where they operate.
GloBE Taxpayers and Eligibility Criteria
GloBE taxpayers consist of Constituent Entities or Joint Venture Groups located in Indonesia and forming part of an MNE Group. A group becomes subject to GloBE if it meets the minimum revenue threshold of EUR 750 million in at least two of the four years preceding the year in which the GloBE rules apply.
Entities that meet the criteria are required to apply for the addition of GloBE Taxpayer status through the Taxpayer Portal within the prescribed period. If such application is not submitted, the status may be determined ex officio by the Directorate General of Taxes.
Administration of Taxpayer Status
This regulation governs three main matters:
- Addition of GloBE Taxpayer status
- Changes to administrative information (identity, group structure, address, and contact details)
- Revocation of status where the group no longer meets the eligibility requirements.
All processes are carried out electronically through the DGT tax administration system and may be processed automatically or based on an administrative review. An application for the addition of GloBE Taxpayer status must be submitted no later than 9 months after the end of the first GloBE Fiscal Year in which the MNE Group meets the applicable requirements.
GloBE Tax Return Filing Obligations
GloBE taxpayers are required to submit an Annual GloBE Income Tax Return (GloBE CIT Return), which consists of:
- Main Return Form (GloBE, DMTT, and UTPR)
- Appendices for top-up tax calculation
- Data on GloBE income, covered taxes, SBIE, and other adjustments
The filing must be submitted no later than 4 months after the end of the GloBE tax year, with an option for a 2-month extension.
GloBE Information Return (GIR)
The Ultimate Parent Entity is required to submit a GIR containing comprehensive information on:
- Group structure
- Constituent entity data
- Calculation of the effective tax rate
- Allocation of top-up tax
- Notes on accounting policy elections
The GIR must be submitted no later than 15 months after the end of the fiscal year (or 18 months for the first year of application).
Notification
In addition to the GIR, taxpayers are also required to submit a Notification to the DGT, unless the GIR has already been submitted. The Notification serves as a disclosure of the reporting entity’s identity within the MNE Group.
Top-Up Tax Payment
Top-up tax under the IIR, UTPR, and DMTT must be paid no later than the end of the GloBE tax year using a specific tax account code. This system ensures that each jurisdiction receives its rightful share of the minimum tax.
Post-Filing Adjustments
If there are changes in covered taxes after filing:
- Tax increase → directly adjusted in the current year
- Tax decrease → may result in a recalculation of the effective tax rate and top-up tax
- Material corrections are made through the Additional Current Top-up Tax mechanism
Supervision and Audit
The Directorate General of Taxes has broad authority to conduct supervision, including:
- Requests for data and documents
- Compliance audits
- Analysis of consolidated financial statements
- Monitoring of tax return filings, GIR submissions, and tax payments
In addition, the Directorate General of Taxes may conduct special audits related to the implementation of GloBE in accordance with applicable tax provisions.
Objections and Dispute Resolution
GloBE taxpayers have the right to:
- File objections to tax assessments
- Submit appeals to the tax court
- Request corrections, reductions, or cancellation of tax assessments
These procedures follow the general provisions of Indonesian tax law.
Additional Reporting and Technical Provisions
Some other key provisions include:
- The use of the Rupiah or the consolidated reporting currency
- The use of the Ultimate Parent Entity’s accounting period as the reference period
- A simplified reporting mechanism for the transitional period up to 2028–2030
- Automatic exchange of GIR information between jurisdictions through international agreements
The GloBE regulation marks a major transformation in Indonesia’s international tax system. Through the implementation of a global minimum tax, Indonesia strengthens its position in securing its tax base, preventing tax avoidance practices, and ensuring equal treatment between multinational companies and domestic companies.
PER-6/PJ/2026 effective since May 04, 2026.
For Tax Service assistance, please contact:
Rani Widianti
T. (+6221) 2222-0200
Alvina Oktavia
T. (+6221) 2222-0200
E. alvina.oktavia@shinewing.id
