New Circular Letter: Taxpayers Subject to Comprehensive Examination
JAKARTA, DDTCNews - Director General of Tax Circular Letter Number SE-8/PJ/2026 sets out the criteria for taxpayers subject to comprehensive examination, simple examination and automatic examination during the implementation of material compliance supervision (pengawasan kepatuhan material/PKM in Indonesian).
Material compliance supervision refers to the supervision of taxpayers' tax obligations, conducted through both formal compliance examination and material compliance examination in respect of obligations falling due before the current tax year.
"Material compliance examination within the scope of PKM shall be conducted through comprehensive examinations, simple examinations or automatic examinations for the tax years before the current tax year," reads SE-8/PJ/2026, as cited on Friday (17/7/2026).
Comprehensive examination refers to a material compliance examination covering all taxes that constitute a taxpayer's obligations in their entirety, including through business process analysis, financial statement analysis and/or transfer pricing analysis, for tax years prior to the current tax year.
Comprehensive examination is conducted in respect of strategic taxpayers and certain other taxpayers that satisfy the following criteria:
- high-risk taxpayers;
- taxpayers indicated to conduct transactions influenced by a special relationship;
- taxpayers constituting part of a group taxpayer;
- taxpayers undertaking business restructuring;
- taxpayers filing a loss tax return;
- individual taxpayers who are high-wealth individuals;
- taxpayers receiving accelerated tax refunds;
- taxpayers with a turnover exceeding IDR4.8 billion;
- taxpayers receiving tax incentives; and/or
- at the discretion of the head of the Tax Office (kantor pelayanan pajak/KPP in Indonesian).
Comprehensive examination shall be completed within a maximum of 22 business days from the date of the supervision order until the examination result report (laporan hasil penelitian/LHPt in Indonesian) is issued.
Further, automatic examination refers to a material compliance examination covering one or more taxes and one or more taxable periods on a limited basis.
Automatic examination is conducted on concrete data as regulated under the Director General of Tax regulation concerning the follow-up on concrete data, namely PER-18/PJ/2025.
In general, the 3 categories of data classified as concrete data are:
- tax invoices that have received approval through the DGT's information system but have not been or are not filed by the taxpayers in the periodic VAT returns;
- withholding tax or income tax collection receipts that have not been or are not filed by the issuer of the withholding tax or income tax collection receipts in the periodic income tax returns; and/or
- proof of transactions or tax data that may be used to calculate a taxpayer's tax liabilities.
Automatic examination shall be completed within a maximum of 1 business day from the date the supervision order is issued until the examination result report is issued.
Finally, simple examination refers to a material compliance examination covering several or all taxes for a specified scope of taxpayers, including through business process analysis and/or financial statement analysis, in respect of the current tax year and/or prior tax years.
Simple examination is implemented in respect of taxpayers other than those that fulfil the criteria for comprehensive examination and automatic examination.
Simple examination shall be completed within a maximum of 10 business days from the date of the supervision order until the examination result report is issued, encompassing activities such as examination of calculation accuracy and comparative analysis, equalisation analysis and/or examination of the correctness of the application of statutory provisions.
On another note, SE-8/PJ/2026 is a new circular letter relating to taxpayer supervision, issued to follow up on the issuance of MoF Reg. 111/2025, to support the implementation of coretax, implement the results of the evaluation of tax supervision and to incorporate feedback from stakeholders.
SE-8/PJ/2026 was enacted by Director General of Tax Bimo Wijayanto on 15 July 2026. (dik)
