BERITA TERKINI
JAKARTA, DDTCNews - DTC has once again convened a discussion titled DDTC Strategic Tax Dialogue: Overview of GMT and What to Do About It on Thursday (15/5/2025). The discussion was attended by representatives of several multinational enterprises (MNEs) operating in Indonesia.
The discussion revealed that most MNEs in Indonesia still lack a sufficient understanding of the global minimum tax. Moreover, the majority have yet to assess its potential impact.
Representatives of MNEs also expressed concerns regarding the administrative aspects of the global minimum tax regime as well as the potential burden of the top-up tax.
“Survey results indicate that MNEs continue to face uncertainty. Their understanding remains incomplete, largely because the nature of the regulation is inherently complex and dissemination efforts have been limited,” claimed Director of DDTC Fiscal Research & Advisory, B. Bawono Kristiaji.
According to Bawono, the global minimum tax constitutes part of a broader reform of the international tax system. In recent years, jurisdictions have sought to reform international taxation in response to digitalisation and the growing complexity of cross-border transactions.
In 2024, member jurisdictions of the Inclusive Framework agreed to implement the global minimum tax under Pillar Two: Global Anti-Base Erosion (GloBE) as a common approach.
Considering that the global minimum tax has been agreed as a common approach, jurisdictions are not strictly required to adopt the global minimum tax. However, they are expected to respect its implementation by other jurisdictions.
Under the common approach scheme, Indonesia has inevitably moved to adopt the global minimum tax through the Minister of Finance Regulation (MoF Reg.) 136/2024.
MoF Reg. 136/2024 reflects the adoption of the GloBE Model Rules, developed by the Organisation for Economic Co-operation and Development (OECD) and agreed upon by Inclusive Framework member jurisdictions.
The provisions under MoF Reg. 136/2024 are widely regarded as complex and encompass unfamiliar terminology not commonly used in Indonesia’s tax regulations. Some terms remain untranslated due to the absence of equivalent expressions in Indonesian.
“Upon closer examination, many concepts refer to European frameworks, given that they were developed by the OECD and are not always fully contextualised for Indonesia,” Bawono noted.
On account of this complexity, DDTC, as a research- and knowledge-based tax institution, has encouraged MNEs to focus on strengthening their capacity building.
Capacity building is deemed a critical element in applying any regulation, including the global minimum tax. Without capacity building and sufficient understanding, no regulation can be effectively enforced.
To enhance taxpayers’ capacity, Bawono urged MNEs to begin simulating the calculation and administration of the global minimum tax using financial data from the 2024 tax year.
The results of such simulations, he added, can serve as a foundation for exercising global minimum tax obligations in the 2025 tax year. (rig)
