REGULATION OF THE DIRECTOR GENERAL OF TAXES NUMBER PER-23/PJ/2025 ON THE DETERMINATION OF DOMESTIC TAX SUBJECTS AND FOREIGN TAX SUBJECTS

Whereas Regulation PER-23/PJ/2025 aims to clarify the General Provisions and Tax Procedures by re-regulating the provisions concerning the determination of the status of domestic tax subjects and foreign tax subjects.

The following are the main provisions of Regulation PER-23/PJ/2025:

Domestic Tax Subjects are:

1. Individuals, whether Indonesian citizens (WNI) or foreign nationals (WNA), who:
2. reside in Indonesia, meaning they are domiciled, have their main activities, or carry out daily activities in Indonesia;
3. are present in Indonesia for more than 183 days within a 12-month period, whether continuously or intermittently; or
4. in a tax year, are present in Indonesia and have the intention to reside in Indonesia, which can be evidenced by documents in the form of:
5. Permanent Stay Permit Card (KITAP);
6. Limited Stay Visa (VITAS) with a validity period of more than 183 days;
7. Limited Stay Permit (ITAS) with a validity period of more than 183 days;
8. a contract or agreement to perform work, business, or activities in Indonesia for more than 183 days;
9. other documents that can demonstrate an intention to reside in Indonesia, such as a residential lease agreement exceeding 183 days or documents evidencing the relocation of family members.
10. Entities that are established or domiciled in Indonesia as stated in their deed of establishment, and that have their head office or center of management and control in Indonesia.
11. An undivided inheritance, as a single unit, replacing the party entitled thereto.

Foreign Tax Subjects are:

1. Individuals who do not reside in Indonesia;
2. Foreign nationals who are in Indonesia for no more than 183 days within a 12-month period;
3. Indonesian citizens who are outside Indonesia for more than 183 days within a 12-month period and meet the following requirements:

1. Permanently residing outside Indonesia;
2. Having the main center of personal, economic, and/or social activities outside Indonesia, which can be evidenced by:
3. Spouse, children, and/or close relatives by blood or marriage reside outside Indonesia;
4. Source of income originates from outside Indonesia;
5. Being a member of religious, educational, social, and/or community organizations recognized by the government of the respective country;
6. Having a place to carry out daily activities outside Indonesia;
7. Being a taxpayer in another country or jurisdiction, which can be evidenced by a certificate of domicile or other documents indicating taxpayer status issued by the tax authority of that country or jurisdiction;
8. Other specific requirements, namely:
9. Has fulfilled tax obligations on all income earned while the Indonesian citizen was a domestic taxpayer;
10. Has obtained a Certificate confirming that the Indonesian citizen meets the requirements to become a Non-Resident Taxpayer, issued by the Directorate General of Taxes (DGT);
11. An entity that is neither established nor domiciled in Indonesia; and
12. An entity that is neither established nor domiciled in Indonesia, which conducts business through a permanent establishment in Indonesia, or which can earn income from Indonesia without conducting business through a permanent establishment in Indonesia.

Income earned from Indonesia by an Indonesian citizen who is outside Indonesia for more than 183 days is subject to income tax in accordance with the tax regulations applicable to non-resident taxpayers.

In the case of an individual or entity that is a taxpayer in a country/jurisdiction that is a partner under a Tax Treaty (DTA) and also a domestic taxpayer, the taxpayer status is determined based on the provisions of the relevant Tax Treaty.

PER-23/PJ/2025 was enacted on 9 December 2025 and comes into effect as of its enactment.

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