SW Indonesia Tax Update PMK 37 Tahun 2025

MINISTER OF FINANCE REGULATION NUMBER 37 YEAR 2025 (MOF 37/2025) ON THE APPOINTMENT OF OTHER PARTIES AS INCOME TAX COLLECTORS AND PROCEDURES FOR COLLECTING, DEPOSITING, AND REPORTING INCOME TAX COLLECTED BY OTHER PARTIES ON INCOME RECEIVED OR OBTAINED BY DOMESTIC MERCHANTS WITH TRADING MECHANISMS THROUGH ELECTRONIC SYSTEMS

This regulation aims to facilitate public participation in development through tax payments, fulfill the principles of legal certainty, justice, ease and simplicity of administration, and improve the efficiency and effectiveness of tax collection. Therefore, arrangements are made for the appointment of other parties who are organizers of trading through electronic systems as income tax collectors as well as procedures for collecting, depositing, and reporting income tax on income received or obtained by domestic merchants with trading mechanisms through electronic systems.

The following are some of the main provisions included in MoF 37/2025:

1. Appointment of Other Party as Income Tax Collector

1. Other Parties domiciled inside and outside the territory of the Republic of Indonesia that meet certain criteria are appointed by the Minister of Finance as Income Tax Article 22 collectors to collect, deposit, and report taxes on income received or obtained by Domestic Merchants with the mechanism of Trading Through Electronic Systems.
2. The appointment of Other Parties has certain criteria, namely:
   • Trading Through Electronic System Operator that uses an escrow account to collect income;
   • Has a transaction value with users of services providing electronic facilities used for transactions in Indonesia exceeding a certain amount within 12 (twelve) months; and/or
   • Has traffic or accessors exceeding a certain amount within 12 (twelve) months. 
3. The Minister of Finance will set limits on transaction value and/or the amount of traffic or accessors exceeding a certain amount.

2. Criteria for Domestic Merchants and Submission of Information by Domestic Merchants to Other Parties

1. Domestic Merchants, including shipping or expedition service companies, insurance companies, and other parties that conduct transactions with buyers of goods and/or services through Electronic Commerce, are individuals or entities that meet the following criteria:
   • receive income using a bank account or similar financial account; and
   • conduct transaction using an internet protocol address in Indonesia or using a telephone number with an Indonesia country telephone code.
2. Domestic Merchants must submit information in the form of Tax Identification Number (NPWP) or Citizen Identification Number (NIK) and correspondence address to Other Parties appointed as tax collectors.
3. Other information that needs to be considered by Domestic Merchants:
   • If the Domestic Merchant is an individual Taxpayer having Gross Revenue in the current Fiscal Year up to IDR 500,000,000.00 (five hundred million rupiah), a statement letter confirming this amount is also required to be submitted.
   • If the Domestic Merchant has a certificate of exemption from withholding and/or collection of Income Tax, a certificate of the exemption is also required to be submitted.
4. The submission of the information is made by the Domestic Merchant before the income is received or obtained, and must be submitted again at the beginning of the following Fiscal Year if the income received or obtained with Gross Distribution does not exceed IDR 4,800,000,000.00 (four billion eight hundred million rupiah) in 1 (one) Fiscal Year and the Domestic Merchant has a certificate of exemption from withholding and/or collection of Income Tax. 
5. In case the Domestic Merchant has a Gross Turnover exceeding IDR 500,000,000.00 (five hundred million rupiah), the Domestic Merchant shall submit information to the Other Party in the form of a statement letter no later than the end of the month in which the Gross Turnover exceeds IDR 500,000,000.00 (five hundred million rupiah). 

3. Income Tax Collection

1. The income received or obtained by Domestic Merchants in connection with transactions conducted through the Electronic Trading System Operator is subject to Income Tax Article 22 and must be collected, deposited, and reported by the Other Party.
2. The amount of Income Tax Article 22 is 0.5% (zero-point five percent) of the Gross Turnover received or obtained by Domestic Merchants listed in the billing document, excluding value added tax and sales tax on luxury goods. Income Tax Article 22 is payable when the payment is received by the Other Party.
3. Income Tax Article 22 can be calculated as Income Tax payment in the current year for Domestic Merchants.
4. In the case that the collection of Income Tax Article 22 is final in accordance with the provisions of taxation laws and regulations, the income tax is part of the final Income Tax settlement for Domestic Merchants. Income Tax that is final includes:
   • Income Tax as stipulated in Article 4 paragraph (2) of the Income Tax Law on the rental of land and/or building, construction service business, or purchase of goods and/or services from taxpayers having Certain Gross Turnover; or
   • Income Tax as stipulated in Article 15 of the Income Tax Law.
5. In the case that there is a difference between the final Income Tax and Income Tax Article 22 that has been collected by Other Parties, the difference must be paid by the Domestic Merchant as final Income Tax in accordance with the provisions of laws and regulations in the field of taxation. 
6. Furthermore, if there is an overpaid tax, the overpaid tax can be submitted for a refund of the tax overpayment that should not be payable in accordance with the provisions of taxation laws and regulations. 
7. If the transaction uses a currency other than Rupiah, the amount of Income Tax Article 22 is calculated by converting it into Indonesia Rupiah using the exchange rate determined by the Minister as the basis for payment of import duties, value added tax on goods and services and sales tax on luxury goods, export duties, and Income Tax, which are in effect at the time of payment.
8. Domestic Merchants are obliged to deposit the shortage of Income Tax that is final and report the shortage of Income Tax that has been deposited using the Unification Monthly Income Tax Return. If the Domestic Merchants do not carry out the obligation to deposit and report, the Domestic Merchants are subject to sanctions in accordance with the provisions of laws and regulations in the field of taxation.

9. The Other Party does not collect Income Tax Article 22 on the income received or obtained by the Domestic Trader in connection with the transaction of:
   • sales of goods and/or services by domestic individual Taxpayers who have Gross Distribution up to IDR 500,000,000.00 (five hundred million rupiah) in the current Tax Year and have submitted a statement letter;
   • sales of delivery or expedition services by a domestic individual Taxpayer as a partner of a technology-based application company that provides transportation services;
   • sales of goods and/or services by Domestic Merchants who submit information on certificate of exemption from withholding and/or collection of Income Tax;
   • sales of phone credit and starter packs;
   • sales of gold jewelry, gold bars, jewelry whose materials are not entirely made of gold, gemstones, and/or other similar stones, conducted by gold jewelry manufacturers, gold jewelry traders, and/or gold bullion entrepreneurs; and/or
   • transfer of rights to land and/or building or agreement to bind the sale and purchase of land and/or building and its amendments.

4. Tax Collection Documents

1. Domestic Merchants are obliged to make billing documents for the sale of goods and/or services with the mechanism of Trading Through Electronic Systems, in the form of billing documents on behalf of Domestic Merchants generated through electronic communication facilities or other electronic systems provided by Other Parties. The billing document is a document equated with proof of Income Tax Article 22 collection for Domestic Merchants.
2. The billing document must be made by including at least the following information:
   • Number and date of the billing document;
   • Name of the other party;
   • Account name of the Domestic Merchant;
   • Identity of the buyer of goods and/or services in the form of name and address;
   • Type of goods and/or services, total selling price, and discount; and
   • Amount of Income Tax Article 22 for each Domestic Merchant.

3. The invoice document whose transaction is not subject to collection of Income Tax Article 22 shall still be equated with proof of collection of Income Tax Article 22.
4. In case there is correction or cancellation of invoice documents, Domestic Merchants shall be obliged to make correction or cancellation document that refers to the corrected or canceled invoice document through electronic communication facilities or other electronic systems provided by Other Parties and used for Trading Through Electronic Systems transactions.

5. Information on the number of the bill correction or cancellation document is filled in by using the number generated through electronic communication facilities or other electronic systems provided by Other Parties.
6. Income Tax Article 22 stated in the correction document may be calculated as Income Tax payment in the current year for Domestic Merchants or may be part of the final Income Tax settlement, for Domestic Merchants subject to final Income Tax.

5. Procedures for Depositing Income Tax and Submission of Periodic Tax Return for Other Parties

1. Other Parties are required to submit the following information:
   • Tax Identification Number (NPWP) or Citizen Identification Number (NIK), correspondence address, statement letter stating that the Domestic Merchant has Gross Turnover in the current Fiscal Year up to IDR 500,000,000.00 (five hundred million rupiah) or exceeds IDR 500,000,000.00 (five hundred million rupiah) for individual taxpayers, and/or certificate of exemption from withholding and/or collection of Income Tax;
   • Other information in the form of name, account name, and/or country of choice of the Domestic Merchant; NPWP or TIN and/or correspondence address of the Other Party; and electronic mail address or telephone number of the buyer of goods/services;
   • Information contained in the document equated with proof of collection of Income Tax Article 22 and/or correction document or invoice cancellation document equated with proof of collection of Income Tax Article 22;
   • Income Tax Article 22 that has been collected and deposited to the Director General of Taxes in accordance with the provisions of taxation laws and regulations.
2. Such information shall be reported in the Unification Monthly Income Tax Return.

6. Sanction

Other Parties that do not comply with the provisions of the collection, deposit, and submission of Income Tax Article 22 shall be subject to sanctions in accordance with the provisions of laws and regulations in the field of taxation and the provisions of laws and regulations regarding private scope electronic system providers.

This regulation was promulgated on July 14, 2025, and come into effect on the date of promulgation.

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