No Legal Standing, MK Rejects Judicial Review of Tax Attorneys

JAKARTA, DDTCNews - The Constitutional Court (Mahkamah Konstitusi/MK in Indonesian) has declared that Mahamuddin, as the applicant, does not have legal standing to submit a judicial review of the minister of finance's authority to regulate attorney competency under the norm of Article 44E paragraph (2) subparagraph e of the General Provisions and Tax Procedures Law (GPTP Law), as last amended by the HPP Law.

Constitutional Court Chief Justice, Suhartoyo, in pronouncing Constitutional Court Decision Number 328/PUU-XXIV/2026, stated that the applicant had been unable to demonstrate any loss of constitutional rights that would be suffered in connection with the entry into force of Article 44E paragraph (2) subparagraph e of the GPTP Law, as last amended by the HPP Law.

"The applicant was unable to set out clearly and adequately the alleged loss of constitutional rights arising from the entry into force of Article 44E paragraph (2) subparagraph e," said Suhartoyo on Tuesday (29/9/2026).

Suhartoyo stated that the Constitutional Court found no evidence indicating that the applicant, as a self-employed individual, was potentially unable to obtain the facility to appoint a taxpayer attorney as a result of the entry into force of the phrase '...as well as certain competencies that must be possessed by an attorney as referred to in Article 32 paragraph (3a) shall be stipulated by or based on a Minister of Finance Regulation' in Article 44E paragraph (2) subparagraph e of the GPTP Law, as last amended by the HPP Law.

The Constitutional Court noted that the applicant's application largely contained descriptions relating to the regulation of taxpayer attorneys under the minister of finance regulation.

"Further, the Court found no evidence of any event actually experienced or potentially to be experienced by the applicant that bore a connection to the applicant's occupation or profession in relation to the question of the constitutionality of the phrase within the norm of the article against which the judicial review is filed," said Suhartoyo.

Based on the foregoing, the Constitutional Court, through Decision Number 328/PUU-XXIV/2026, declared that the applicant does not have legal standing to submit the application and that the application shall not be further considered.

"Declaring the applicant's application inadmissible," reads the operative part of Decision Number 328/PUU-XXIV/2026. (dik)