Tax Update - February 2025

Mar 03, 2025 05:15:40 pm
Manhajul Islam, S. Ak - BATS Consulting

INTRODUCTION

At the beginning of 2025, the Indonesian government has introduced several new tax policies aimed at supporting economic growth, enhancing taxpayer compliance, and providing incentives for specific sectors. In response to global and national economic dynamics, tax regulations continue to be adjusted to effectively stimulate businesses and the public.

This newsletter summarizes the latest Minister of Finance Regulations (PMK) issued in February 2025, covering various aspects of taxation, including income tax incentives (PPh Article 21), changes in Value Added Tax (VAT) regulations, incentives for electric vehicles, and new procedures for tax audits and investigations.

Some key policies highlighted in this edition include:

  1. PMK Number 10 of 2025 – Government-borne PPh 21 incentives for employees in specific sectors as an economic stimulus.
  2. PMK Number 11 of 2025 – Adjustments to the tax base calculation for Value Added Tax (VAT).
  3. PMK Number 12 of 2025 – VAT and Luxury Goods Sales Tax (PPnBM) incentives for battery-based electric vehicles with specific local content requirements (TKDN).
  4. PMK Number 13 of 2025 – Government-borne VAT for the sale of landed houses and apartment units.
  5. PMK Number 15 of 2025 – Reformation of tax audit procedures, introducing three new types of tax audits.
  6. PMK Number 17 of 2025 – Regulations on the investigation of tax crimes to enhance legal certainty and taxpayer compliance.

With these latest regulations, taxpayers, both individuals and businesses, are expected to understand the policy changes and optimize the benefits provided. This newsletter aims to deliver clear and concise information regarding the latest tax policies and their implications for various business sectors and the broader public.

 

MFR NUMBER 10 OF 2025 CONCERNING INCOME TAX ARTICLE 21 ON CERTAIN INCOME BORNE BY THE GOVERNMENT IN THE CONTEXT OF ECONOMIC STIMULUS FOR THE 2025 FISCAL YEAR

          The government provides Government-Borne Income Tax 21 incentives which will take effect from February 4, 2025. This incentive is given on all gross income in 2025 received by employees with a period of January 2025 to December 2025.

          This incentive is given to certain Employees, both Permanent Employees and/or Non-Permanent Employees of the Employer with certain criteria, namely:

Conducting business activities in the industrial sector:

1.     Footwear;

2.     Textiles and apparel;

3.     Furniture; or

4.     Leather and leather goods.

Certain Permanent Employees must meet the following criteria:

a.     Have an TIN or NIN that has been integrated with the Directorate General of Population and Civil Registration and the Directorate General of Taxes;

b.     Receiving a fixed and regular gross income of not more than IDR 10,000,000 on:

1.     January 2025 Tax Period, for certain employees who start working before January 2025; or

2.     The first month of employment Tax Period, for certain employees who have just worked in 2025; and

c.      Do not receive Income Tax 21 incentives borne by other governments.

Certain Non-Permanent Employees must meet the following criteria:

a.     Have a TIN or NIN that has been integrated with the Directorate General of Population and Civil Registration and the Directorate General of Taxes;

b.     Receive wages in the amount:

1.     The average of 1 day is not more than IDR 500,000 in terms of wages received on a daily, weekly, unit, or wholesale basis; or

2.     Not more than IDR 10,000,000 in terms of wages received or earned on a monthly basis;

c.      Do not receive Income Tax 21 incentives borne by other governments.

Employers are required to report the use of incentives for each Tax Period in the Periodic Tax Return every month.

 

MFR NUMBER 11 OF 2025 CONCERNING OTHER VALUE PROVISIONS AS THE BASIS FOR IMPOSITION OF TAXES AND CERTAIN AMOUNTS OF VALUE-ADDED TAX

          After the Government provides the provisions of the Other Value Tax Base of 11/12 which applies to VAT calculations, in addition to the VAT imposed with the Other Value Tax Base which has been regulated separately and VAT with a certain amount.

          MFR Number 11 of 2025 provides similar provisions that apply to VAT with the separately regulated Other Value Tax Base and VAT with a certain amount. The amended provisions include:

1.     MFR Number 75/MFR.03/2010 concerning Other Values as the Basis for Imposition of Tax;

2.     MFR Number 102/MFR.011/2011 concerning Other Values as a Basis for Imposition of Tax on the Utilization of BKPTB from Outside the Customs Area in the Customs Area in the form of Imported Story Films and Submission of Import Story Films, as well as the Basis for Collection of Income Tax 22 on Import Story Film Import Activities;

3.     MFR Number 6/MFR.03/2021 concerning the Calculation and Collection of VAT and Income Tax on Submission in connection with the sale of Credit, Starter Packs, Tokens, and Vouchers;

4.     Regulation of the Minister of Finance Number 173/MFR.03/2021 concerning Procedures for Payment, Payment, and Administration of Value Added Tax or Value Added Tax and Sales Tax on Luxury Goods on the Delivery of Taxable Goods and/or Taxable Services from and/or to Free Trade Zones and Free Ports;

5.     Regulation of the Minister of Finance Number 62/MFR.03/2022 concerning VAT on the Delivery of Certain LPG;

6.     Regulation of the Minister of Finance Number 63/MFR.03/2022 concerning VAT on the Delivery of Tobacco Products;

7.     Regulation of the Minister of Finance Number 66/MFR.03/2022 concerning Value Added Tax on the Delivery of Subsidized Fertilizers for the Agricultural Sector;

8.     Regulation of the Minister of Finance Number 79 of 2024 concerning Tax Treatment in Operating Cooperation.

 

VAT with a Certain Amount:

1.     Regulation of the Minister of Finance Number 62/MFR.03/2022 concerning Value Added Tax on the Delivery of Certain Liquefied Petroleum Gas;

2.     Regulation of the Minister of Finance Number 64/MFR.03/2022 concerning Value Added Tax on the Delivery of Certain Agricultural Products;

3.     Regulation of the Minister of Finance Number 65/MFR.03/2022 concerning Value Added Tax on the Delivery of Used Motor Vehicles;

4.     Regulation of the Minister of Finance Number 71/MFR.03/2022 concerning Value Added Tax on the Delivery of Certain Taxable Services;

5.     Regulation of the Minister of Finance Number 41 of 2023 concerning Value Added Tax on the Delivery of Collateral Expropriated by Creditors to Collateral Buyers;

6.     Regulation of the Minister of Finance Number 48 of 2023 concerning Income Tax and/or Value Added Tax on the Sale/Delivery of Gold Jewellery, Gold Bars, Jewellery Made of Materials Not Made of Gold, Gemstones and/or Other Similar Stones, as well as Services related to Gold Jewellery, Gold Bars, Jewellery Made of Materials Not Made of Gold, and/or Gemstones and/or Other Similar Stones,  carried out by Gold Jewellery Manufacturers, Gold Jewellery Traders, and/or Gold Bullion Entrepreneurs;

7.     Regulation of the Minister of Finance Number 81 of 2024 concerning Tax Provisions in the Context of the Implementation of the Core System of Tax Administration.

 

MFR NUMBER 12 OF 2025 CONCERNING VALUE-ADDED TAX ON THE DELIVERY OF CERTAIN FOUR-WHEELED BATTERY-BASED ELECTRIC MOTOR VEHICLES AND CERTAIN BUS BATTERY-BASED ELECTRIC MOTOR VEHICLES AS WELL AS SALES TAX ON LUXURY GOODS ON THE DELIVERY OF CERTAIN TAXABLE GOODS CLASSIFIED AS LUXURY IN THE FORM OF CERTAIN LOW-CARBON ELECTRIC EMISSION FOUR-WHEELED MOTOR VEHICLES BORNE BY THE GOVERNMENT FOR THE 2025 FISCAL YEAR

          The government again provides VAT and PPnBM incentives for the Delivery of Certain Four-Wheeled-Based Electric Motorized Vehicles and Certain Buses. This is regulated in MFR Number 12 of 2025.

          KBL that receives this facility must meet the TKDN value criteria as follows:

a.     Certain Four-Wheeled Battery-Based KBL with a minimum TKDN value of 40%;

b.     Certain Bus Battery-Based KBL with a minimum TKDN value of 40%;

c.      KBL Based on Certain Bus Batteries with a minimum TKDN value of 20% to less than 40%.

So there are 2 schemes in this VAT incentive, namely:

1.     Electric Cars and Electric Buses with a minimum TKDN (Domestic Component Level) of 40%, then VAT BORNE BY THE GOVERNMENT is 10%. So that the buyer only pays VAT of 2%.

2.     Electric Buses with a minimum TKDN (Domestic Component Level) of 20% to less than 40%, then VAT BORNE BY THE GOVERNMENT is 5%. So that the buyer only pays VAT of 7%.

In addition, this MFR also regulates Sales Tax incentives on Luxury Goods Borne by the Government for the Delivery of Certain Low Carbon Emission Four-Wheeled Motorized Vehicles. Facilities that are 3% of the Selling Price.

 

MFR NUMBER 13 OF 2025 CONCERNING VALUE-ADDED TAX ON THE HANDOVER OF LANDED HOUSES AND FLATS UNITS BORNE BY THE GOVERNMENT FOR THE 2025 FISCAL YEAR

The government continues the incentives that are always given every year, namely Government-Borne VAT on VAT payable on the handover of landed houses and flats for the 2025 Fiscal Year.

This facility is provided on VAT when the handover occurs when:

1.     the signing of the sale and purchase deed made by the official who made the land deed; or

2.     the signing of the binding agreement on the sale and purchase in full before the notary,

and an actual transfer of rights to use or control ready-to-live landed houses or ready-to-live flats as evidenced by the minutes of the handover from January 1, 2025 to December 31, 2025.

This Government-Borne VAT is given only for TAX BASE up to IDR 2 billion with a maximum selling price of IDR 5 billion, as for the details:

1.     100% for the submission of the handover minutes from January 1, 2025 to June 30, 2025.

2.     50% for the handover whose handover minutes date is carried out from July 1, 2025 to December 31, 2025

Taxable Entrepreneurs who make this submission are required to make a Tax Invoice in accordance with the provisions of the law and the VAT realization report borne by the Government.

 

MFR NUMBER 15 OF 2025 CONCERNING TAX AUDIT

The government has issued new provisions regarding Tax Audit which will be promulgated on February 10, 2025. This provision replaces the provisions that have been previously issued, including:

1.     MFR Number 17 of 2014 concerning Tax Audit Procedures;

2.     MFR Number 256 of 2014 concerning Procedures for Land and Building Tax Audit and Research;

3.     MFR Number 18 of 2021 concerning Job Creation Implementation Regulations

Points of Change in MFR 15 of 2025:

1.     In Article 2 Chapter II, there are 3 types of new tax audits, namely:

a.     Complete audit – Thoroughly test tax compliance with all posts in the tax return and/or SPOP. For example, the examination of the Annual Income Tax Return, VAT Periodic Return, Luxury Tax, and Land Tax. The period of this examination is 5 months.

b.     Focused examination – Examine one or more posts in the tax return or SPOP in depth. The tax auditor will provide a written notice to the taxpayer regarding the post being inspected. The term is 3 months.

c.      Specific checks – Conducted to verify a specific post in a tax return, tax data, or other tax liability with a simpler procedure. For example, verification of withholding Income Tax 21 on employee salaries. The term is 1 month.

2.     In Article 6 Chapter IV, tax audits for other, such as transfer pricing and financial transaction engineering, now have an extension period of up to 4 months.

3.     Article 12 of the Fourth Part which stipulates that taxpayers must submit the requested data within 1 month. If the deadline is exceeded, the documents provided may be considered non-submitted. The tax auditor is also required to prepare a Minutes that record the fulfillment of documents by taxpayers.

4.     In situations where the documents provided are insufficient or make the examination difficult, the tax auditor may calculate taxable income by position. If indications of tax crimes are found, the examiner may propose an examination of the Preliminary Evidence.

5.     In Article 18 paragraph (2) of the Eighth Section, the period for taxpayers response to the Audit Result Notification Letter (SPHP) is changed from 7 working days to 5 working days.

 

MFR NUMBER 17 OF 2025 CONCERNING THE INVESTIGATION OF CRIMINAL ACTS IN THE FIELD OF TAXATION

          The government provides legal certainty for the implementation of criminal investigations in the field of taxation. MFR Number 17 of 2025 was issued to replace the previous provision, namely MFR Number 55/MFR.03/2016 concerning Procedures for Requesting the Termination of Criminal Investigation in the Field of Taxation.

          This MFR has 10 Chapters which include:

1.     General Provisions

2.     Scope

3.     Investigation Basis

4.     Investigation Activities

5.     Termination of Investigation for the Sake of State Revenue

6.     Request for Information on Losses on State Revenue

7.     Handling Investigations Outside Indonesian Jurisdiction or Across State Borders

8.     Document Submission

9.     Transitional Conditions

10.  Closing Provisions

Investigations in the field of Taxation can be carried out by DGT Investigators who have the authority to carry out the investigation process. Types of Tax Crimes that Can Be Investigated include:

1.     Submission of incorrect or incomplete tax returns;

2.     Use of fictitious Tax Invoices;

3.     Not depositing the tax that has been collected;

4.     Manipulation of bookkeeping or Financial Statements;

5.     Violation of Article 39A of the KUP Law (Document Falsification).

The Investigation Stage is as follows:

1.     Examination of Preliminary Evidence;

2.     Issuance of Investigation Warrants;

3.     Examination and Collection of Evidence;

4.     Submission of Files to the Prosecutors Office

If the suspect or taxpayer is willing to pay off all state losses and pay administrative sanctions, the Minister of Finance can submit an application for termination of the investigation to the Attorney General.

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