Not New Taxes: 3 Digital Transaction Tax Collection Schemes
THE GOVERNMENT has reportedly planned to involve state-owned banks, private banks, fintech firms and e-commerce platforms in collecting tax on digital transactions starting 9 November 2026.
The news emerged after the President's Special Envoy for Climate and Energy, Hashim Djojohadikusumo, announced plans to expand digital tax collection at a forum last week.
"What is called digital taxation, digital tax, will be implemented shortly on 9 November. All government banks, private banks and all fintech platforms, including Shopee, Lazada, GoTo and so forth, must participate in collecting and must remit taxes that have not previously been collected," he said.
Does this policy imply that all interbank transfers made by the public will be subject to tax? The answer is no.
It is important to understand that the collection of tax on digital economy transactions has its own provisions on the parties designated as collection agents, the parties subject to collection and the types of transactions that constitute taxable objects.
The government's authority to designate other parties as withholding agents or collection agents is governed by Article 32A of the General Provisions and Tax Procedures (GPTP) Law, as inserted by Law 7/2021 on the Harmonisation of Tax Regulations (Harmonisasi Peraturan Perpajakan/HPP in Indonesian).
Such other parties include those directly involved in or facilitating transactions by providing the means of transaction, including transactions conducted electronically.
At present, there are several tax collection mechanisms for digital transactions in Indonesia, namely VAT on electronic commerce (perdagangan melalui sistem elektronik/PMSE in Indonesian), the tax collection system for cross-border digital transactions (sistem pemungutan pajak transaksi digital luar negeri/SPP-TDLN in Indonesian) and Article 22 Income Tax on marketplace transactions.
The following is an explanation of each of these three mechanisms.
VAT on E-Commerce
VAT on e-commerce is the collection scheme applied by the government to levy VAT on the utilisation of intangible taxable goods and taxable services from outside the customs territory within the customs territory via e-commerce.
The collection of VAT on e-commerce was first implemented in 2020 under Gov. Reg. in Lieu of Law 1/2020. The regulations governing VAT collection on e-commerce have been continuously refined in line with regulatory developments. Currently, VAT collection on e-commerce is implemented pursuant to MoF Reg. 81/2024.
To implement this policy, the government, through the director general of taxes, designates e-commerce entrepreneurs as other parties required to collect VAT from consumers, remit the tax collected and file the collection and remittance with the Directorate General of Taxes (DGT).
E-commerce entrepreneurs are designated as other parties if they conduct transactions with Indonesian consumers valued at more than IDR600 million per year or IDR50 million per month and/or have traffic exceeding 12,000 per year or 1,000 per month.
Currently, 245 e-commerce entrepreneurs have been designated as other parties and are actively remitting VAT on e-commerce to the DGT. The total VAT collected by these e-commerce b entrepreneurs from January to September 2026 reached IDR9.54 trillion.
E-commerce entrepreneurs apply VAT at the standard rate, namely 12% of the alternative tax base (dasar pengenaan pajak/DPP in Indonesian) set at 11/12 of the selling price, import value or consideration.
VAT on e-commerce is not a new tax, given that previously VAT on the utilisation of intangible taxable goods and taxable services from outside the customs territory had to be remitted by consumers themselves via self-remittance, rather than by the e-commerce entrepreneurs.
SPP-TDLN
In addition to the VAT on e-commerce scheme, the government has also prepared the tax collection system for cross-border digital transactions (sistem pemungutan pajak transaksi digital luar negeri/SPP-TDLN in Indonesian) to levy VAT on the utilisation of intangible taxable goods and taxable services from outside the customs territory within the customs territory.
Unlike the VAT on e-commerce scheme, which designates e-commerce entrepreneurs as other parties, under the SPP-TDLN scheme the DGT designates banks and non-bank financial institutions that process payments, namely issuers, as the other parties responsible for collecting VAT.
VAT collection is conducted by banks and non-bank financial institutions following confirmation from the SPP-TDLN that VAT is due on an overseas digital transaction in connection with the utilisation of intangible taxable goods or taxable services from outside the customs territory.
The introduction of the SPP-TDLN does not give rise to double VAT collection. This is because the utilisation of intangible taxable goods or taxable services from outside the customs territory on which VAT has already been collected by an e-commerce entrepreneur will not be subject to further VAT collection via the SPP-TDLN.
Accordingly, VAT collection through the SPP-TDLN is focused on the utilisation of intangible taxable goods and taxable services from outside the customs territory within the customs territory that have not previously been covered under the VAT on e-commerce scheme.
At present, 6 issuers have been designated by the DGT as other parties under the SPP-TDLN, namely BRI, BNI, BSI, Bank Mandiri, BTN and LinkAja. These 6 issuers are required to collect VAT at 11/111 of the payment for the supply of intangible taxable goods or taxable services from outside the customs territory.
Going forward, the number of issuers will continue to grow in line with the sandboxing and stabilisation process undertaken by issuers together with PT Jalin Pembayaran Nusantara, as the developer of the SPP-TDLN.
Article 22 Income Tax Collection by Marketplace Operators
Tax collection in the digital economy sector is not limited solely to digital goods and digital services from overseas. Tax collection is now also being applied to entrepreneurs earning income from trading activities conducted through marketplace platforms.
With the entry into force of MoF Reg. 37/2025, the government has designated 4 marketplace platforms to collect Article 22 income tax at 0.5% on the gross turnover derived by domestic merchants from trading activities on the respective marketplace.
The 4 marketplace platforms designated as other parties responsible for collecting Article 22 income tax are Tokopedia, Shopee, Lazada and Blibli. Although the ministerial regulation on Article 22 income tax collection has been in force since 2025, collection only commenced on 1 October 2026.
For domestic merchants, the Article 22 Income Tax of 0.5% already collected by the marketplace may be credited as a tax credit or applied as part of the settlement of final income tax, including the final income tax for micro, small, and medium enterprises (MSMEs), which carries the same rate of 0.5%.
Accordingly, Article 22 Income Tax on marketplace transactions is not a new tax; rather, it changes the tax payment mechanism from one previously based on self-remittance by traders to direct collection by marketplace providers at the time of transaction. (rig)