VAT CLASS

MoF Reg. 49/2026: VAT on Cross-Border Digital Transactions via SPP-TDL

Tuesday, 28 July 2026 | 11.00 WIB

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The minister of finance has officially issued procedures for collecting value added tax (VAT) on cross-border digital transactions through a new system. The system in question is the tax collection system for cross-border digital transactions (sistem pemungutan pajak atas transaksi digital luar negeri/SPP-TDLN in Indonesian).

These procedures are set out in MoF Reg. 49/2026. In addition to being an implementing regulation of Pres. Reg. 68/2025, this ministerial regulation also gives effect to the authority of the Minister of Finance under Article 32A paragraph (1) of the General Tax Provisions Law to appoint other parties to withhold, collect, remit and/or file taxes.

In the considering section, it is stated that there are cross-border digital transactions subject to VAT but whose tax has not yet been collected optimally. Accordingly, a new system is required to optimise such collection.

“Tax collection system for cross-border digital transactions, hereinafter abbreviated to SPP-TDLN, is a system that uses technology to collect value added Tax on cross-border digital transactions,” reads an excerpt from Article 1 number 17 of MoF Reg. 49/2026.

An SPP-TDLN operator is a legal entity stipulated under the president of the Republic of Indonesia regulation governing the tax collection system for cross-border digital transactions (Pres. Reg. 68/2025).

Pursuant to Article 3 of Pres. Reg. 68/2025, the administration of the SPP-TDLN is implemented by a subsidiary of a state-owned enterprise (SOE) in the field of financial services technology and payment systems. The BUMN subsidiary in question is PT Jalin Pembayaran Nusantara.

Pursuant to Article 9 of MoF Reg. 49/2026, the SPP-TDLN operator is responsible for the management, security, confidentiality and protection of data. The SPP-TDLN operator retains data pursuant to statutory provisions.

Which Transactions Are Subject to VAT via the SPP-TDLN?

The SPP-TDLN constitutes a technology-based system used to collect VAT on cross-border digital transactions. VAT collection is conducted on the utilisation of:

intangible taxable goods from outside the customs territory in the form of digital goods by a goods beneficiary; and/or
taxable services from outside the customs territory in the form of digital services by a service beneficiary.

This scheme applies specifically to transactions where VAT collection has not been conducted by electronic commerce (e-commerce or perdagangan melalui sistem elektronik/PMSE in Indonesian) entrepreneurs that have previously been appointed as other parties (VAT collection agents) by the minister, commonly known as e-commerce VAT.

“The collection of VAT through the SPP-TDLN ... constitutes the collection of VAT on cross-border digital transactions, whose collection of VAT is conducted by other than PMSE entrepreneurs that have been appointed as other parties by the minister,” reads an excerpt from Article 5 paragraph (1) of MoF Reg. 49/2026.

Accordingly, the SPP-TDLN targets gaps in cross-border digital transactions that have not yet been covered by the existing e-commerce VAT collection mechanisms. From 2020 to 30 June 2026, the total e-commerce VAT remitted amounted to IDR42.01 trillion.

Who Is Responsible for Collecting VAT under the SPP-TDLN?

The role of collecting, remitting and filing VAT under the SPP-TDLN scheme is carried out by the issuer appointed as another party by the minister of finance. Pursuant to Article 3 paragraph (4) of MoF Reg. 49/2026, this appointment authority is delegated to the director general of taxes.

The issuer is defined as a bank or non-bank institution that provides services to facilitate payments for cross-border digital transactions conducted by goods beneficiaries and/or service beneficiaries.

“To be appointed as the other party, the issuer … must undergo a development period and a stabilisation period,” reads an excerpt from Article 4 paragraph (1) of MoF Reg. 49/2026.

The development period constitutes a period to develop the Issuer's system to be connected with the SPP-TDLN according to the technical specification documents of the SPP-TDLN operator, which starts no later than 1 (one) business day after the receipt of such documents..

The stabilisation period constitutes a sandboxing period to ensure interconnection and security between the issuer's system and the SPP-TDLN according to the criteria set by the SPP-TDLN operator.

The SPP-TDLN operator coordinates with the sandboxing implementing team concerning the results of the stabilisation period to be reviewed at a minimum once. The appointment of the issuer as the other party is conducted by considering:

an official report containing the statement of readiness of the issuer’s system submitted by the SPP-TDLN operator; or
the results of the review conducted by the sandboxing implementing team.

How Do the VAT Collection Mechanisms Work via the SPP-TDLN?

Pursuant to the provisions under Article 6 of MoF Reg. 49/2026, VAT is deemed payable at the time the SPP-TDLN operator provides confirmation to the other party that a particular cross-border digital transaction is subject to VAT.

VAT collected through the SPP-TDLN must be taken into account by the cross-border digital transaction entrepreneur in the price or payment for the supply of intangible taxable goods and/or taxable services payable by the goods beneficiary and/or service beneficiary.

Pursuant to Article 7 paragraph (2) of MoF Reg. 49/2026, from the time of supply onwards, the other party is required to collect VAT using the formula of 11/111 multiplied by the price or payment that already includes VAT.

VAT collection through the SPP-TDLN does not apply to cross-border digital transactions that are not subject to VAT or are exempt from VAT pursuant to statutory provisions.

Where a cross-border digital transaction is conducted using foreign currency, the amount of VAT collected must be converted to rupiah using the exchange rate under the minister of finance decree applicable at the time confirmation is given.

What Data Must Be Submitted by the Other Party?

The other party is required to submit a number of data items to the SPP-TDLN operator for confirmation no later than the time the other party authorises payment for the cross-border digital transaction. The data concerned consists of:

data on cross-border digital transactions; and/or
data on domestic transactions used fin the context of the mapping and analysis of cross-border digital transactions in the form of a fund transfer and remittance.

Pursuant to the provisions under Article 8 paragraph (3) of MoF Reg. 49/2026, the data submitted to the SPP-TDLN operator for confirmation constitutes data related to taxation, comprising:

data on cross-border digital transactions(reference number; transaction nominal amount; transaction currency; entrepreneur’s name; entrepreneur’s country code; payment type; transaction date and time; other party's name; other party's country code; original transaction reference; and destination transaction type);
domestic transaction data in the form of fund transfers (reference number; transaction amount; transaction currency; payment type; transaction date and time; other party country code; original transaction reference; destination transaction type; originating institution; and destination institution); and/or
data on domestic transactions in the form of remittance (reference number; transaction nominal amount; transaction currency; payment type; transaction date and time; other party's country code; original transaction reference; destination transaction type; originating institution; destination institution; and remittance surcharge).

If data other than the above is available in the system, the other party is required to submit data comprising: the entrepreneur’s name; the entrepreneur’s country code; originating institution; destination institution; remittance surcharge; type of goods; entrepreneur classification; reentrepreneur’s registered name; entrepreneur’s registration number; entrepreneur’s email address; entrepreneur’s municipality; entrepreneur’s telephone number; identity of the entrepreneur’s institution; and/or entrepreneur’s financial institution.

Where the data on the destination transaction type in the data on domestic transactions is in the form of a fund transfer or remittance, the other party submits the data in the form of the domestic and foreign destination account numbers in the form of hashed values.

The SPP-TDLN operator provides confirmation no later than 1 day after the other party submits the request for confirmation . The Directorate General of Taxes (DGT) is authorised to access such data through the SPP-TDLN operator.

“Mechanisms for the application of the hash function .... shall be determined by the SPP-TDLN operator by referring to security standards pursuant to statutory provisions,” reads an excerpt from Article 8 paragraph (8) of MoF Reg. 49/2026.

What About the Documents and Tax Remittance?

In respect of the VAT collected, the other party is required to issue documents containing the other party's identity, the entrepreneur's identity, the identity of the goods and/or service beneficiary, the date of collection, the reference number as well as the tax base (dasar pengenaan pajak/DPP in Indonesian) and the collected VAT.

The identity of the goods and/or service beneficiary comprises the name; residential address or electronic mail address; and account number or telephone number in the event that there is no account number. The mention of VAT collection in the documents may be included separately from the tax base or as part of the payment value.

The collection of VAT documents may be in the form of a bill statement and/or similar documents, insofar as they contain the required data. The documents constitute certain documents equivalent to the tax invoice.

VAT in such documents constitutes creditable input VAT, provided that the consumer's electronic mail address or telephone number is registered in the DGT's administration and the applicable provisions on input VAT crediting are satisfied.

Pursuant to Article 11 of MoF Reg. 49/2026, in the event that there are circumstances resulting in changes in the VAT that has been collected, the other party is required to amend or replace or cancel certain documents equivalent to the tax invoice.

Certain documents equivalent to the tax invoice refer to certain documents equivalent to the tax invoice that are amended or replaced or cancelled.

In terms of remittance, the other party is required to remit the collected VAT through the SPP-TDLN operator no later than 7 days from the date the confirmation is given. The remittance of VAT constitutes part of the obligation to remit VAT to the state treasury.

The submission of data and VAT remittance by the other party is treated as:

the filing of the periodic VAT return for VAT collection agents and other parties that do not constitute taxable persons (pengusaha kena pajak/PKP in Indonesian), in the event that the other party does not constitute a taxable person; or.
a part of the integral unit of the periodic VAT return for taxable persons, in the event that the other party constitutes a taxable person.

Subsequently, the SPP-TDLN operator is required to remit the VAT (received from the other party) to the state treasury. The VAT is remitted to the tax deposit no later than 7 days from the date the VAT is remitted by the other party. Remittance is conducted using a tax payment slip stating:

the name and taxpayer identification number (TIN) of the SPP-TDLN operator; and
tax account code 411618 and remittance type code 100.

Pursuant to Article 15 of MoF Reg. 49/2026, the SPP-TDLN operator is required to file the collection of VAT in the periodic VAT return. The periodic VAT return must, at a minimum, contain data and/or information comprising the tax base and the collected VAT. Such data and/or information is submitted in a consolidated manner. The collected VAT listed in the periodic VAT return is remitted to the state treasury.

What Happens If VAT Is Incorrectly Collected?

MoF Reg. 49/2026 governs two conditions that may trigger a refund of VAT that should not otherwise be collected, namely where a transaction is partially or completely cancelled, or where VAT has already been collected on a transaction that should not be subject to collection through the SPP-TDLN.

In both conditions, the party from whom tax is collected may apply for a refund to the SPP-TDLN operator through the other party (issuer). This application is subsequently followed up by the other party and/or the SPP-TDLN operator.

Where such conditions give rise to a discrepancy in the periodic VAT return already filed, the SPP-TDLN operator is required to file an amended periodic VAT return, complete with an explanation and detailed reasons for the amendment.

However, the amendment of the periodic VAT return cannot be carried out in two conditions, namely where the periodic VAT return has been subject to audit measures, or where the overpaid periodic VAT return is filed beyond a period of 2 years before the statute of limitations for assessments expires.

“In the event that the SPP-TDLN Operator cannot amend the periodic tax return …, the application for the refund submitted by the party subject to the collection shall be settled by the SPP-TDLN operator,” reads an excerpt from Article 16 paragraph (6) of MoF Reg. 49/2026.

In respect of an amendment to a periodic VAT return resulting in a tax overpayment, the SPP-TDLN operator may apply for a refund of tax overpayment that should not otherwise be payable to the DGT. However, this application shall not be followed up on with the issuance of a notice of tax overpayment assessment. The overpayment is treated as a deduction against the tax payment liability in the next normal periodic VAT return that has not yet been filed.

Conversely, where the SPP-TDLN operator self-amends a periodic VAT return and this results in the tax amount being greater, the SPP-TDLN operator is subject to administrative penalties pursuant to the applicable provisions.

What If a Transaction Has Not Been Subject to Collection Through the SPP-TDLN?

It should be noted that the VAT obligation on cross-border digital transactions does not automatically cease merely because a transaction has not yet been covered by the SPP-TDLN. MoF Reg. 49/2026 affirms that the utlisation of intangible taxable goods and/or taxable services from outside the customs territory whose VAT has not been collected by the other party remains subject to VAT pursuant to the generally applicable tax provisions.

In addition, this ministerial regulation also affirms that all rights and/or obligations of taxpayers pursuant to tax provisions apply mutatis mutandis to the SPP-TDLN operator and/or the other party in carrying out the collection of VAT on cross-border digital transactions through the SPP-TDLN.

How Is the SPP-TDLN Operator Remunerated?

As compensation for operating this system, the SPP-TDLN operator is provided with a fee, the amount of which is determined by the Minister of Finance based on the performance of the SPP-TDLN and by taking into account the VAT remittances successfully deposited into the state treasury.

From a budgetary perspective, the service fee is allocated in the budget execution document (daftar isian pelaksanaan anggaran/DIPA in Indonesian) of the budget section of the state general treasurer (Bagian Anggaran Bendahara Umum Negara/BA BUN in Indonesian) for the Management of Special Transactions of the Payment of Fees of the SPP-TDLN.

The Minister of Finance, acting as the budget user of the state general treasurer (Pengguna Anggaran BUN/PA BUN in Indonesian), designates the DGT as the assistant budget user of the state general treasurer (Pembantu Pengguna Anggaran BUN/PPA BUN), whilst also appointing the unit head official at the DGT as the proxy of budget user of the state general treasurer (Kuasa Pengguna Anggaran BUN/KPA BUN in Indonesian) for that budget item.

The payment mechanism commences with a reconciliation between the KPA BUN and the SPP-TDLN operator no later than 5 business days in the following month. The results of the reconciliation are outlined in the official report of reconciliation.

Based on the reconciliation results, the KPA BUN determines the fee value by means of a decision letter. Where any overpayment or underpayment is identified, an adjustment is made to the fee payment for the following period.

Following reconciliation, the SPP-TDLN operator submits the claim for fees no later than 10 business days of the following month, accompanied by receipts, the official report of reconciliation, a statement letter of absolute responsibility and tax invoices.

The claim is formally and substantively assessed by the commitment-making official (Pejabat Pembuat Komitmen/PPK in Indonesian), then forwarded as a payment request letter (surat permintaan pembayaran/SPP in Indonesian) to the payment order signatory official (Pejabat Penanda Tangan Surat Perintah Membayar/PPSPM in Indonesian) for further assessment.

Based on the SPP, the PPSPM shall conduct a formal assessment of the administrative completeness and correctness of the claim for fee and the availability and allocation of the budget in the DIPA BA BUN for the Management of Special Transactions of the Payment of Fees of the SPP-TDLN.

If the SPP is declared complete and correct, the PPSM shall issue and submit the SPM to the state treasury office accompanied by a statement letter of expenditure responsibility. The disbursement mechanisms for payments of fees are conducted pursuant to the ministerial regulation on procedures for the disbursement of the state budget charged to the BA BUN at the state treasury office.

From the taxation perspective, payments of fees constitute a withholding tax object. Meanwhile, the supply of taxable services by the SPP-TDLN operator to the government remains subject to VAT pursuant to the applicable provisions. All payments of fees must also be recorded in the accounting and financial reporting by the relevant KPA BUN.

“The KPA BUN for the Management of Special Transactions of the Payment of Fees of the SPP-TDLN shall maintain financial accounting and reporting of the payment of Fees pursuant to the Ministerial Regulation concerning the special transaction accounting system,” reads Article 23 of MoF Reg. 49/2026.