BERITA TERKINI
JAKARTA, DDTCNews - DDTC held a discussion titled Strategic Dialogues: Global Minimum Tax Readiness in 2025 on Thursday (8/5/2025), attended by representatives from several multinational enterprise (MNE) groups.
The agenda, structured as a focus group discussion (FGD), served as a platform for interaction between DDTC and MNE taxpayers to deliberate on the challenges arising from the implementation of the global minimum tax.
Further, the Indonesian government has issued MoF Reg. 136/2024 as the domestic legal basis for the global minimum tax. The event also provided an opportunity for DDTC to gather feedback from taxpayers regarding their level of readiness and the constraints they face.
Director of DDTC Fiscal Research & Advisory, B. Bawono Kristiaji, explained that MoF Reg. 136/2024 represents an adoption of the GloBE Model Rules developed by the Organisation for Economic Co-operation and Development (OECD). The regulation, which draws heavily on OECD documentation, introduces numerous new terms and inherent complexities.
“Numerous foreign terminologies and the regulation’s limited readability pose significant challenges in understanding MoF Reg. 136/2024. We see the need for capacity building to address the complexity of the global minimum tax. This discussion is intended to provide an equal platform to examine shared challenges,” he said on Thursday (8/5/2025).
Capacity building has emerged as a critical aspect in the implementation of any regulation, including the global minimum tax. Without adequate capacity among taxpayers to understand and interpret regulations, effective implementation would be difficult to achieve.
The complexity of the global minimum tax is further compounded by its interaction with domestic tax provisions across jurisdictions.
As such, a solid grounding in international taxation concepts, commercial accounting standards and tax principles is essential to fully comprehend the framework.
Moreover, the global minimum tax entails multiple stages of analysis. It is not merely about identifying companies subject to an effective tax rate below 15% to be subsequently subject to a top-up tax.
Instead, it involves several steps, including: (i) determining whether an MNE falls within scope; (ii) calculating GloBE income or loss; (iii) determining adjusted covered taxes; (iv) computing the effective tax rate (ETR); and (v) determining the top-up tax.
From the government’s perspective, particularly the tax authority, capacity building is equally crucial. This is especially relevant given the potentially large number of MNEs in Indonesia that fall within the scope of the global minimum tax.
Accordingly, a strong grasp of the provisions on the global minimum is necessary to ensure effective assistance, compliance monitoring and the prevention and resolution of disputes between the tax authority and taxpayers. See ‘The Significance of the Global Minimum Tax’. (rig)
