KEBIJAKAN PAJAK

Government Must Clarify the Design of Marketplace Art. 22 Income Tax

Muhamad Wildan
Rabu, 02 Juli 2025 | 22.00 WIB
Government Must Clarify the Design of Marketplace Art. 22 Income Tax
<p>From left to right: Director of Counseling, Services, and Public Relations of DJP Rosmauli; host Ardianto Wijaya; Head of Taxation at the Indonesian E-Commerce Association (idEA) Daniel William Legawa; and Director of DDTC Fiscal Research &amp; Advisory B. Bawono Kristiaji in the <em>Arah Angin</em> talk show broadcast by TVRI, Wednesday (2/7/2025) evening.</p>

JAKARTA, DDTCNews - Tax authorities across various jurisdictions have increasingly involved marketplace providers in collecting taxes from taxpayers conducting business through digital platforms.

Director of DDTC Fiscal Research and Advisory, B. Bawono Kristiaji, noted that such involvement could serve as an effective instrument to address the shadow economy.

“The most significant stumbling block to our tax revenues has long been the shadow economy. Here, it does not necessarily refer to illegal activities, but also to economic activities that are legal yet remain undetected or outside the radar of the tax authority,” Bawono claimed during the Arah Angin talk show broadcast by TVRI on Wednesday (2/7/2025).

In practice, many countries adopt a minimum of 3 approaches to involving marketplace providers in tax collection. First, engaging platforms in outreach efforts to improve compliance.

Second, requiring platforms to collect and share tax-related data with the tax authority. Third, mandating marketplace providers to collect tax on transactions conducted through the marketplace.

Among these approaches, taxpayers tend to exhibit higher compliance when marketplace providers are formally appointed as collection agents responsible for collecting taxes on transactions through the marketplace.

However, before Indonesia proceeds with mandating marketplace providers to collect Art. 22 Income Tax, the government should first conduct a thorough review of merchant behaviour in the marketplace.

“We need to understand merchant behaviour, such as their average turnover and whether they operate across multiple platforms. This is crucial to ensure the effectiveness of the collection of Art. 22 Income Tax when it is applied,” Bawono explained.

He further emphasized the need for greater clarity concerning the policy design of Art. Income Tax that will be collected by marketplace providers.

According to Bawono, the government must clearly affirm Art. 22 Income Tax and the existing micro, small and medium enterprise (MSME) final income tax regime. Such affirmation is necessary to prevent the risk of double taxation.

“Will Art. 22 Income Tax replace the existing regime, or will both apply concurrently? If both are imposed simultaneously, there is indeed a risk of double taxation,” he noted.

Nevertheless, if Art. 22 Income Tax collected by marketplaces can be credited against the final income tax payable, the risk of double taxation could be mitigated.

The government must therefore provide clear guidance on how Art. 22 Income Tax collected by the marketplace interacts with the MSME final income tax regime, particularly since the 0.5% final tax scheme for MSMSe remains in force.

“It is as if two systems are running in parallel. How will this be implemented in practice? That is what needs to be clarified in the policy design,” Bawono added.

Responding to concerns over potential double taxation, the Director of Tax Dissemination, Service and Public Relations of the Directorate General of Taxes (DGT), Rosmauli, assured that Art. 22 Income Tax collection would not result in double taxation for MSME entrepreneurs.

“We consistently avoid double taxation, specifically, for domestic taxes,” she stated.

Rosmauli explained that Art. 22 Income Tax collected by marketplace providers constitutes a tax credit for the taxpayers subject to the collection.

“For businesses operating both online and offline with turnover exceeding IDR500 million, the 0.5% final income tax continues to apply. If, upon calculation, there is underpaid tax, this constitutes a tax credit against the total tax payable,” she elaborated.

She further stressed that the involvement of marketplace providers is essential to enhancing compliance among marketplace merchants. By appointing marketplaces as Art. 22 Income Tax collection agents, taxpayers would be assisted in exercising their tax obligations.

“We aim to support entrepreneurs. In this case, the government seeks to improve compliance by enabling tax collection through marketplaces. These platforms act as an extension of the tax authority, a partner of the DGT in tax collection,” Rosmauli said.

The Importance of Clarity and Socialisation

Beyond the issue of potential double taxation, Bawono underscored that the government’s most pressing task, together with marketplace providers, is to educate entrepreneurs or merchants operating in the marketplace.

Data from Statistics Indonesia (Badan Pusat Statistik/BPS in Indonesian) indicates that approximately 85% of marketplace sellers have annual turnover below IDR300 million. Moreover, many of them lack basic tax knowledge.

Given these conditions, Bawono emphasized that the regulation on Art. 22 Income Tax collection by marketplace providers must provide clear guidance for merchants in the marketplace.

“We are dealing with parties who may not yet be tax literate. The most important step is to collaborate with marketplace platforms. This will be far more effective. If the DGT and platforms operate separately, implementation becomes difficult. A joint approach is essential to build both the ecosystem and tax awareness,” he concluded.

Meanwhile, the Head of Taxation Division at the Indonesian E-Commerce Association (idEA), Daniel William Legawa, stated that the association is ready to comply with government policies and regulations.

He added that idEA is willing to engage in discussions with the DGT to formulate appropriate policies aimed at improving the compliance of taxpayers constituting marketplace merchants.

“We highly appreciate the opportunity to discuss and provide input as well as collaborate with the tax authority in reviewing the most appropriate timing for implementation,” Daniel said.

Should the government designate marketplace providers as Art. 22 collection agents, Daniel noted that the industry would require a minimum of 2 years to conduct socialisation and education for merchants.

“As marketplace operators, we oversee tens of millions of merchants. This cannot be done overnight. We need sufficient time for adjustment, campaigns and socialisation. Timing will be critical, from policy issuance to its effective date,” he concluded. (dik)

Editor : Dian Kurniati
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