BERITA TERKINI
JAKARTA, DDTCNews – Director General of Taxes Bimo Wijayanto’s appeal to taxpayers not to be concerned about receiving a letter of inquiry (surat permintaan penjelasan atas data dan/atau keterangan/SP2DK in Indonesian) has garnered public attention over the past week. According to Bimo, taxpayers need only provide clarification by submitting transaction evidence that can explain the data held by the Directorate General of Taxes (DGT).
Bimo said the issuance of an SP2DK is a follow-up to data and information obtained by the DGT from various parties. The data originates from ministries and institutions (kementerian dan lembaga/K/L in Indonesian), local governments, associations and banking.
“We have been working with almost all data providers [including] ministries, institutions, associations and local governments. So why are we being complained about by the public for sending so many SP2DKs? There is no need to be afraid," said Bimo.
According to Bimo, the DGT has now collected millions of data points and pieces of information from various institutions. Such data serve as one of the bases for the tax authority to request explanations from taxpayers through SP2DKs.
Accordingly, taxpayers receiving an SP2DK are requested to provide explanations addressing the data in question. Relevant transaction evidence may be submitted to clarify the information obtained by the DGT.
"Taxpayers may submit transaction evidence that can address the SP2DK, as we obtain millions of transaction records every day," Bimo remarked.
Bimo highlighted that SP2DKs are not intended to place an undue burden on the public. Rather, the letters constitute one of the DGT's efforts to remind taxpayers to comply with the applicable provisions and exercise their tax obligations pursuant to the prevailing regulations.
On another note, the DGT reportedly issued 539,733 SP2DKs to taxpayers between 1 January and 27 October 2026. An SP2DK is a letter issued by a tax office (kantor pelayanan pajak/KPP in Indonesian) to request explanations of data and/or details from taxpayers in connection with indications that their tax obligations may not have been fulfilled pursuant to the provisions.
The majority of these SP2DKs were issued to request explanations or details from taxpayers regarding data obtained by the DGT from various sources.
The SP2DKs received by taxpayers follow a standard letter structure or format, as set out in the Appendix of MoF Reg. 111/2025. Nevertheless, the contents of an SP2DK may vary depending on the findings or analysis conducted by tax officials at the relevant local KPP.
In addition to the news surrounding the issuance of SP2DKs, several other tax issues also attracted readers' attention over the past week. These include the taxation of digital transactions and the proposal to decentralise the Tax Court.
The DGT has issued a clarification regarding the issue of tax collection through all financial institutions and e-commerce platforms starting 9 November 2026.
DGT Director of Tax Dissemination, Service and Public Relations, Inge Diana Rismawanti, stated that the DGT is currently implementing a new system called the tax collection system for cross-digital transactions (sistem pemungutan pajak atas transaksi digital luar negeri/SPP-TDLN in Indonesian), which is designed to collect VAT on the utilisation of digital taxable goods or services from abroad.
"This policy is not a new tax, does not change the VAT rate, and is not intended to collect tax on all foreign transactions," Inge claimed.
Bonuses totalling IDR158.3 billion awarded to athletes and coaches who won medals at the 2026 Asian Games and Asian Para Games are subject to income tax.
Inge said that the bonuses received by the successful athletes constitute income subject to income tax. Procedures for the calculation of Article 21 Income Tax on such bonus income refer to MoF Reg. 168/2023 concerning Instructions for the Implementation of Withholding Tax on Income in Connection with Employment, Services and Activities of Individuals.
"Accordingly, the bonuses are subject to Article 21 Income Tax if the recipients are individual taxpayers," she remarked.
The DGT is of the view that handling tax disputes is more effective when centralised at the Tax Court in Jakarta. This was stated in response to a proposal by the Supreme Court (Mahkamah Agung/MA in Indonesian) to decentralise the Tax Court, either by establishing regional tax courts or by integrating them with regional administrative courts (tata usaha negara/TUN in Indonesian).
Bimo stated that tax disputes need to be handled in Jakarta given that 55.8% of appeal and lawsuit applications to the Tax Court are submitted by taxpayers domiciled in Jakarta. Further, Article 4 of the Tax Court Law also permits trials to be held outside the court's domicile. At present, trials outside the domicile may be conducted in Yogyakarta and Surabaya.
"Some 55% of cases are in Jakarta. So, in the current context, trials in Jakarta are more efficient and more effective," said Bimo.
Director General of Taxes Decree Number KEP-239/PJ/2026 provides taxpayers with the opportunity to reduce administrative penalties arising from under-disclosure of assets in the voluntary disclosure programme (program pengungkapan sukarela/PPS in Indonesian).
This facility is valid until the end of 2027, exclusively for taxpayers who under-disclosed assets in connection with their participation in the PPS Policy II. The penalty reductions granted are 100%, 50% or 25%.
“Administrative penalties listed in notices of tax assessment based on audit findings on assets that have not been or are under-disclosed as stipulated under MoF Reg. 196/2021 concerning Procedures for the Implementation of the Taxpayer Voluntary Disclosure Programme issued in the period between 8 October 2026 and 31 December 2027 and on the principal amount of the relevant taxes payable, paid or remitted until 31 December 2027," reads KEP-239/PJ/2026.
The DGT has recorded that the majority of tax disputes between taxpayers and the tax authority in recent years continue to revolve around issues of nexus assessment.
Bimo stated that out of a total of 39,537 disputes at the tax court between 2021 and Q3/2026, some 10,117 disputes, or 25.59%, related to audit methods and techniques, including equalisation and reconciliation techniques.
"The primary category is methods and techniques for nexus assessment. This requires methodology to scrutinise bookkeeping, supporting evidence for the bookkeeping, technical bookkeeping, accounting standards and reconciliation from accounting to taxation. That is the majority, accounting for 25.59%,” Bimo stated.
Bimo has revealed that Indonesia has reached an agreement with Singapore to follow up on misinvoicing and transfer pricing issues.
In his view, both issues have become a concern for Indonesia and Singapore. The two countries consider that addressing them is necessary to achieve fairness in taxation and equitable tax competition.
"There is goodwill on the part of the Singapore Prime Minister to discuss 3 matters. First, a joint resolution regarding forest and land fires. Second, transfer pricing. Third, misinvoicing. These have become bilateral issues, framed in terms of tax fairness and equitable tax competition," said Bimo. (dik)
