A Preview of Indonesian Tax Regulation Updates | VOL. 3/2025

Latest Minister of Finance’s Guidelines for Tax Audit: simplified amendment and restatement of preceding regulations

The Minister of Finance (MoF) Regulation No. 15 of 2025 (MoF Reg. 15/2025) is issued to simplify, reinstate and provide certainty with regards to tax audit (including land and building tax).

The regulation entirely revokes and replaces:

• MoF Regulation No. 17/PMK.03/2013 (MoF Reg. 17/2013) as lastly amended by Article 105 of MoF Regulation No. 18/PMK.03/2021 – regarding Tax Audit Guidelines, and
• MoF Regulation No. 256/PMK.03/2014 (MoF Reg. 256/2014) regarding Audit and Investigation Guidelines for Land and Building Tax.

MoF Reg. 15/2025 includes provisions similar to the preceding regulations, among others: (i) authority, purpose and types of audit, (ii) scope of audit, (iii) audit criteria, (iv) audit standards, (v) audit duration, (vi) rights and obligations of tax authority and taxpayer in an audit, (vii) guidelines on the audit implementation and performance – including the steps, letters, and documents required during the process up to its completion. It covers the audit of all types of taxes – including carbon, land and building, and import tax.

The regulation stipulates conditions when a tax audit would be conducted – such as in case of tax overpayment reported in the tax return, changes to the fiscal year, accounting method and reappraisal of
fixed assets, concrete information causing the unpaid or underpaid tax, etc. Please see Article 4 of MoF Reg. 15/2025 for more details.

All on-going Tax Audit before the issuance of this MoF Regulation shall continue to be processed based on the preceding regulations MoF Reg. 17/2013 (as amended) and MoF Reg. 256/2014, where applicable.

Major changes under MoF Reg. 15/2025 that are different from the preceding regulations are, among others:

1. Types of tax audit are now divided into 3 types, as briefly described below:
   • Complete audit, to thoroughly (secara mendalam) examine the entire tax compliance as stated in the tax returns with an audit duration of 5 months since the Audit Notification Letter (Surat Pemberitahuan Pemeriksaan/SP2) is delivered to the taxpayer,
   • Focused audit, to thoroughly (secara mendalam) examine the tax compliance of certain part of the tax return with an audit duration of 3 months since the SP2 is delivered to the taxpayer, and
   • Specific audit, to simply (secara sederhana) verify the tax compliance of specific part of the tax return or certain tax obligations with an audit duration of 1 month since the SP2 is delivered to the taxpayer.
2. The duration for tax audit can be extended to a maximum of 4 months if the audit is relating to: (i) taxpayers within the same group; and/or (ii) taxpayers indicated to have conducted transfer pricing and/or other special transactions that indicates certain financial engineering.
3. All books, documents, and/or records requested by the tax auditor must be provided (partially or wholly) within 1 month as of the date of the letter of request (surat permintaan).
4. If the documents provided to the tax auditor are deemed insufficient for the tax auditor to assess the taxable income, the tax auditor may calculate the taxable income in their discretion based on the prevailing laws and regulations.
5. Before the Formal Tax Findings (surat pemberitahuan hasil pemeriksaan/SPHP), a Preliminary Findings Discussion (pembahasan temuan sementara) shall be carried out in no later then 1 month before the end of audit duration.
6. The duration for taxpayer to respond to SPHP is now 5 business days (shorter from the previous regulation, i.e. 7 business days) to expedite increase efficiency of the audit process as well as objection mechanism.
7. Following the SPHP response letter, the tax authority must invite the taxpayer to attend the Closing Conference (Pembahasan Akhir Hasil Pemeriksaan) within 3 business days as of the receipt of SPHP response letter (or by the end of the SPHP response letter deadline).

Under this MoF Reg. 15/2025, the tax authority has the obligation to attend the Preliminary Findings Discussions.

The MoF Reg. 15/2025 also provides a similar - but more detailed and simplified provisions regarding discussions with the Audit Quality Assurance team (tim Quality Assurance Pemeriksaan) under a single Article. Discussions with the Audit Quality Assurance team are allowed specifically to discuss disagreement on the legal basis between the taxpayer and tax authority. There are also some additional conditions on when taxpayers are able to request a discussion with the Quality Assurance team. Please see Article 19 of MoF Reg. 15/2025.

Other than the guidelines, the MoF Reg. 15/2025 also provide samples and formats of documents relating to tax audit in its attachment, including format of tax audit extension, form of tax auditor’s ID, form of tax audit instruction letter, tax audit notification, and other forms of letters and documents as may be required in the tax audit process.