SP2DK May Lead to Audit: Criteria Under Latest Circular Letter

JAKARTA, DDTCNews – The activity of requesting an explanation of data and/or details (permintaan penjelasan atas data dan/atau keterangan/P2DK in Indonesian) may progress to a proposal for an audit.

P2DK activities may proceed to an audit where the results of the examination contained in the LHP2DK indicate that the taxpayer has not responded to the SP2DK. In addition, an audit may also be conducted where the taxpayer submits a response that is inconsistent with the results of the examination and/or fails to submit or amend a tax return in accordance with the results of the examination.

P2DK activities may also proceed to an audit where the LHP2DK includes a conclusion that an individual taxpayer has passed away, an individual taxpayer is about to leave or has permanently left Indonesia or a corporate taxpayer has been dissolved.

"The proposal for the audit ... may be in the form of the proposal for an audit for other purposes and/or the proposal for an audit to assess taxpayers' compliance pursuant to the provisions stipulating tax audits," reads the Director General of Taxes Circular Letter Number SE-8/PJ/2026, cited on Sunday (19/7/2026).

Where the proposed audit is an audit to assess taxpayer compliance, the account representative (AR) or assigned Directorate General of Taxes (DGT) employee is required to submit the information necessary for the audit through the DGT's supervisory administration system.

The audit proposal shall be carried out with the approval of the head of the tax office (kantor pelayanan pajak/KPP in Indonesian) through the supervisory administration system.

"DGT supervisory administration system is an information system in the form of an application and/or modules of an application as well as its supporting devices, which constitute part of the DGT administration system used by the DGT to support the implementation of supervision, among others, the coretax administration system supervision module, web-based profile application, DGT digital maps and/or mobile-aided tax officer assistant," reads SE-8/PJ/2026.

For information, P2DK activity is an activity to request an explanation from a taxpayer regarding data and/or information based on examination indicating signs of non-compliance and unfulfilled tax obligations.

A P2DK activity commences with the issuance of an SP2DK to the taxpayer. The SP2DK must be responded to within a maximum of 14 days from whichever of the following events occurs first:

• the date of issuance of the SP2DK where it is delivered via the taxpayer's account;
• the date of delivery of the SP2DK to the taxpayer's e-mail address registered in the DGT administration system;
• the date of the proof of postage of the SP2DK by facsimile where it is delivered by facsimile;
• the date of the proof of postage of the SP2DK by post, forwarding services or courier services with proof of postage; or
• the date of in-person submission of the SP2DK to the taxpayer, representative, attorney, employee or adult family member of the taxpayer.

The period for submitting a response may be extended by a maximum of 7 days where the taxpayer submits a written notification of extension of response to the tax office issuing the SP2DK.

The notification must be received by the tax office issuing the SP2DK before the period for submitting a response to the SP2DK expires. Where the 14-day period has elapsed, the extension notification shall be deemed not to have been submitted. (rig)