BERITA TERKINI
JAKARTA, DDTCNews – The provisions outlined in the Minister of Finance Regulation (MoF Reg.) 15/2025 remain a public concern as the regulation authorises the Director General of Taxes to audit cases even after termination.
Pursuant to the provisions, audits to assess compliance may be deferred and subsequently terminated under specific conditions. The Director General of Taxes, nonetheless, remains able to audit terminated cases, limited to data not disclosed or ruled on by the court.
“The Director General of Taxes may continue to conduct an audit after the audit is terminated as referred to in paragraph (7) [a deferred audit is subsequently terminated],” reads a fragment of Article 23 paragraph (13) of MoF Reg, 15/2025.
In further detail, an audit to assess tax compliance may be deferred in cases of an alleged tax crime. The findings are later followed up with a preliminary audit or tax crime investigation.
A deferred audit is terminated under four conditions. First, the preliminary audit is terminated because the taxpayer discloses the incorrectness of actions as stipulated under Article 8 paragraph (3) of the General Provisions and Tax Procedures Law (GPTP) Law and the disclosure of the incorrectness of actions corresponds to the actual circumstances.
Second, a tax crime investigation is terminated because the taxpayer discloses the incorrectness of actions as stipulated under Article 44A of the GPTP Law or the taxpayer or suspect conducts settlement as stipulated under Article 44B of the GPTP Law.
Third, the preliminary audit or tax crime investigation is terminated because the statute of limitation has elapsed. Fourth, there is a court decision for the tax crime with permanent legal force (other than the court decision that the verdict is not guilty/released from all charges) and a copy of the court decision has been received by the Director General of Taxes.
Pursuant to MoF Reg, 15/2025, the Director General of Taxes may continue an audit after termination for the above-mentioned reasons. The audit, however, is conducted by assessing data not previously disclosed by the taxpayer or ruled on by a court.
Meanwhile, concerns remain over the news about the Coretax system. The DGT asserts that its performance has significantly improved.
Through Written Statement Number KT-11/2025, the DGT claims enhancements in the performance of the Coretax system, as evidenced by reduced latency experienced by taxpayers when accessing the service menu on the DGT Coretax.
“Evaluation and monitoring results indicate improved system performance of the DGT Coretax, in particular, in the process of login, registration, tax invoice issuance, tax return filing and withholding receipt preparation,” stated the DGT.
For instance, login latency has dropped from 4.1 seconds in early February to just 12 milliseconds. The latency of registration has also decreased from 5.8 seconds to 45 milliseconds, whereas the invoice issuance latency has improved from 10 seconds to 1.46 seconds.
Moreover, tax return filing latency reduced from 29.28 seconds to 3.93 seconds, while the withholding receipt preparation latency dropped from 16.6 seconds to only 0.29 seconds.
The DGT has also enhanced the performance of the DGT Coretax, for example, by refining the pre-population process and validating the periodic Article 21/26 Income Tax returns, regenerating documents, validating tax invoice returns and data validation during account activation.
In addition to the two pieces of information above, other tax topics remain in focus, including this year’s declining formal compliance targets, the insistence of the Indonesian Pediatric Society to the Minister of Finance related to the provisions on Article 21 Income Tax and the potential continuation of the use of e-faktur.
The DGT has set the ratio of taxpayer compliance in filing the annual tax return or formal compliance of 81.92% this year.
Director of Tax Dissemination, Services, and Public Relations of the DGT Dwi Astuti stated that the authority would implement various measures to achieve the formal compliance ratio target. However, this year’s target remains lower than last year’s 85.75% ratio.
“The DGT will undertake various steps to encourage compliance with the annual income tax return,” she said.
A total of 5,496 paediatricians constituting members of the Indonesian Pediatric Society (Ikatan Dokter Anak Indonesia/IDAI in Indonesian) have requested the Ministry of Finance to revise the provisions on Article 21 Income Tax on income received by doctors.
Under the Minister of Finance Regulation (MoF Reg.) 168/2023, Article 21 Income Tax on income received by doctors is imposed based on gross income before deductions for profit sharing with hospitals and operating costs.
“This adversely impacts doctors, the majority of whom serve JKN patients,” IDAI stated in a letter addressed to the Minister of Finance.
The DGT is considering continuing e-faktur as a tool for taxable persons (Pengusaha Kena Pajak/PKP in Indonesian) to prepare tax invoices.
Assistant of Minister for Tax Regulation and Law Enforcement Iwan Djuniardi claimed that the decision on e-faktur’s future as an application to prepare tax invoices will be made after an evaluation.
“e-faktur has not been revoked. We will first evaluate. This signifies taxpayers’ behaviour. If it benefits taxpayers, we will continue its use,” said Iwan.
The DGT asserts that the tax audit period serves only as a monitoring and management control tool.
As such, a tax audit that exceeds the period does not warrant terminating the audit or cancelling the notice of tax assessment (Surat Ketetapan Pajak/SKP in Indonesian). This stance is reinforced by the civil review (Peninjauan Kembali/PK in Indonesian) Decision of the Supreme Court (Mahkamah Agung/MA in Indonesian) Number 1633/B/PK/Pjk/2024.
"The Supreme Court has issued a civil review decision with permanent legal force. Under currently applicable rules, this issue should no longer be subject to a lawsuit on account of the Supreme Court’s decision,” remarked Head of the Sub-Directorate of Audit Techniques and Control of the DGT Andri Puspo Heriyanto.
Chairperson of Commission XI of the House of Representatives Mukhamad Misbakhun questioned the contraction in tax revenues, in particular, as customs and excise revenues continued to grow until February 2025.
Misbakhun noted that tax revenues as well as customs and excise revenues typically follow similar trends on the account of being driven by economic activities. In contrast, a decrease in non-tax state revenues (Penerimaan Negara Bukan Pajak/PNBP in Indonesian) is expected due to the decline in commodity prices in the global market.
“Since customs revenues have increased, it is unnatural for tax revenues to fall. Should tax revenues decline, there must be a Coretax technical issue that we have yet to identify,” he stated. (sap)
