New Tax Audit Procedures in Indonesia : Key Updates and Implications for Taxpayers

On February 14, 2025, the Indonesian Minister of Finance (MoF) issued MoF Regulation No. 15 of 2025 (“PMK-15”), introducing new procedures for tax audits. These updates, while retaining many provisions from previous regulations such as MoF Regulation No. 17/PMK.03/2013 as amended by MoF Regulation No. 184/PMK.03/2015, MoF Regulation No. 256/PMK.03/2014, and Article 105 of MoF Regulation No. 18/PMK.03/2021, also bring significant changes, particularly in the categorization of tax audits and timelines.

Understanding these changes is crucial for taxpayers and businesses operating in Indonesia to ensure compliance and preparedness for tax audits under the new framework.

Key Changes in Tax Audit Procedures :

New Categories of Tax Audit

Under PMK-15, the Directorate General of Taxes (DGT) has restructured tax audits into three categories:

• Comprehensive Tax Audit (Pemeriksaan Lengkap): Similar to the previous field tax audit, this is the most extensive type, covering all items in the tax return and/or tax object notification letter (Surat Pemberitahuan Objek Pajak / SPOP).
• Focused Tax Audit (Pemeriksaan Terfokus): Examines one or several specific items from the tax return or SPOP in an in-depth manner.
• Specific Tax Audit (Pemeriksaan Spesifik): Reviews one or several specific tax return or SPOP items but in a simpler manner compared to a focused tax audit.

For focused tax audits, tax auditors must provide written notification to taxpayers specifying the items under review. However, for specific tax audits, certain procedural requirements such as temporary findings discussions and preliminary meetings with taxpayers are waived.

Adjustments in Tax Audit Timelines

Tax Audit Period

PMK-15 divides tax audits into two phases:

• Testing Period: Starts when the Tax Audit Notification Letter (Surat Pemberitahuan Pemeriksaan / SP2) is delivered to the taxpayer and ends when the Tax Audit Findings Notification Letter (Surat Pemberitahuan Hasil Pemeriksaan / SPHP) is issued.
• Closing and Reporting Period: Begins with the issuance of the SPHP and ends with the final Tax Audit Result Report (Laporan Hasil Pemeriksaan / LHP).

The duration for each type of audit is as follows:

• Comprehensive Tax Audit: testing period maximum 5 months (previously 6 months), closing and reporting period maximum 30 working days.
• Focused Tax Audit: testing period maximum 3 months, closing and reporting period maximum 30 working days.
• Specific Tax Audit: testing period maximum 1 month, closing and reporting period maximum 30 working days.

For audits involving group taxpayers and/or transfer pricing, the testing period can be extended for up to 4 months (previously 6 months). Additionally, tax audits related to oil and gas income tax under Production Sharing Contracts (PSC) follow separate regulations.

Deadline for Submitting a Response to SPHP

Taxpayers must now submit a written response to the SPHP within 5 working days of receipt (previously 7 working days with a possible 3-day extension).

Tips: Consult with Indonesian Tax Advisor for comprehensive and professional tax advice.

Mandatory Temporary Findings Discussion (Pembahasan Temuan Sementara)

Before issuing the SPHP, tax auditors must now conduct a Temporary Findings Discussion with taxpayers, at least one month before issuing the SPHP. During this discussion, taxpayers can present supporting documents, explanations, and bring witnesses, experts, or third parties. The discussion outcomes, including submitted documents and taxpayer attendance, must be recorded in the minutes.

This additional step provides taxpayers more time to respond to audit findings, compensating for the reduced deadline for SPHP responses.

Exceptions to the One-Month Rule for Document Submission

Under PMK-15, documents requested by auditors must be submitted within one month. However, two exceptions apply:

• Documents not yet obtained from third parties may be submitted until the minutes of the Closing Conference (Pembahasan Akhir Hasil Pemeriksaan / PAHP) are signed.
• Additional documents that were not initially requested may also be submitted until the minutes of PAHP signing.

Interaction with Tax Audit on Preliminary Evidence of Tax Crime

DGT will not conduct a tax audit for the same fiscal year where a Preliminary Evidence Audit (Bukti Permulaan / Bukper) or tax investigation is ongoing. This ensures that taxpayers are not subject to multiple overlapping audits for the same period.

Ex-Officio Tax Assessment by Auditors

If tax auditors determine taxable income using an ex-officio approach, they must provide evidence that the taxpayer failed to submit the required documents or provided insufficient documentation.

Integration with the Core Tax System

PMK-15 facilitates the use of Indonesia’s Core Tax System by allowing:

• Electronic document submissions for tax audits.
• Digital signatures on audit-related documents.

However, SPHP delivery and taxpayer responses to SPHP must be conducted in person, facsimile, or electronic, and cannot be submitted via postal, courier, or expedition services.

Conclusion

The implementation of PMK-15 introduces new challenges and opportunities for taxpayers in Indonesia. With shorter timelines, stricter audit procedures, and increased reliance on digital systems, businesses must stay vigilant and well-prepared.

At Kusuma & Partners Law Firm, we are committed to guiding our clients through these regulatory changes, ensuring compliance while protecting their financial interests. If you need expert legal assistance with tax audits or any taxation-related matters, contact us today.

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At Kusuma & Partners Law Firm, we understand the complexities of Indonesia’s evolving tax regulations and the critical importance of a well-prepared approach to tax audits. Here’s why clients trust us:

Deep Expertise in Indonesian Tax Law

Our team specializes in Indonesian tax dispute resolution, including tax audits, tax objections, tax appeals, and judicial reviews. With extensive experience handling corporate and individual tax cases, we ensure compliance while minimizing financial risks.

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We proactively assist businesses in managing tax audits by analyzing risks, preparing documentation, and representing clients in discussions with tax authorities. Our goal is to prevent unnecessary tax assessments and disputes.

Comprehensive Legal Support

Beyond tax audits, our firm provides legal services in:

• Monthly and Annual Tax Compliance: Offering end-to-end support for both Monthly and Annual Tax Compliance services, ensuring that you meet your obligations under the Indonesian tax regulation framework.
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Every business is unique, and we offer customized tax compliance and audit strategies tailored to your industry and financial structure.

“DISCLAIMER: This content is for general informational purposes only and is not a substitute for professional advice.”