BERITA TERKINI
JAKARTA, DDTCNews - A tax control framework (TCF) may serve as a solution worth considering for taxpayers in administering the global minimum tax in line with Pillar 2: Global Anti-Base Erosion (GloBE).
DDTC Consulting Manager, Riyhan Juli Asyir, stated that taxpayers covered by the global minimum tax provisions are not required to apply the TCF. Nevertheless, the TCF is crucial for taxpayers to manage the complexity of these global minimum tax provisions.
“The TCF is not regulated under Pillar 2, but on account of the complexity, taxpayers should ideally apply a tax control framework,” Riyhan stated during a seminar titled Closing the Loopholes: Global Tax Reform and the Fate of Transfer Pricing, organised by the Vocational Tax Administration Student Association of the University of Indonesia on Thursday (23/10/2025).
Further, under the Multilateral Convention (MLC) for Amount A of Pillar 1, multinational enterprise (MNE) groups covered by Amount A of Pillar 1 are even required to have apply the TCF.
The TCF is widely recognised and implemented in neighbouring countries, such as Singapore, Australia and Malaysia. However, Indonesia has yet to adopt this framework.
According to Riyhan, one of the urgencies for adopting a TCF is to minimize disputes.
“We can imagine that if the global minimum tax exists without an internal tax control framework mechanism, the potential for tax disputes will be substantial,” Riyhan warned.
With a TCF, taxpayers can better understand the implications of the global minimum tax. This understanding can serve as a foundation for MNE groups when making decisions.
In Indonesia, the global minimum tax officially took effect in 2025 pursuant to MoF Reg. 136/2024, while the tax return (surat pemberitahuan/SPT in Indonesian) related to the global minimum tax is only mandatory starting 30 June 2027.
Nevertheless, please note that taxpayers that constitute constituent entities of multinational groups covered by the global minimum tax must make the additional payment no later than 31 December 2026.
“What we must do is follow all the steps. To calculate how much tax must be paid, we must have completed all the step-by-step requirements of the global minimum tax,” Riyhan stated.
First, taxpayers within the scope of the global minimum tax need to identify the constituent entities within the group. Next, the taxpayers also need to identify the location of each constituent entity and subsequently allocate the profit to those entities.
Further, taxpayers need to determine the GloBE income for each constituent entity and the adjusted covered taxes. The GloBE income and adjusted covered taxes will then be used to calculate the effective tax rate and the outstanding top-up tax.
In the final stage, taxpayers need to allocate the top-up tax payable, whether based on the qualified domestic minimum top-up tax (QDMTT), the income inclusion rule (IIR) or the undertaxed payment rule (UTPR).
Reflecting on the aforementioned complexity, taxpayers need to undertake capacity building to enable all relevant departments to be proficient in the global minimum tax.
Capacity building should involve not only the tax department, but also other departments involved in calculating the financial accounting net income or loss (FANIL).
“Currently, the key aspect for taxpayers is capacity building. Taxpayers must also start establishing a sound internal tax system that enables them to calculate the amount of top-up tax,” Riyhan concluded. (dik)
