New Regulation! DGT Removes Delta Scheme in Tax Return Amendment

JAKARTA, DDTCNews – The Directorate General of Taxes (DGT) has issued the Director General of Taxes Regulation No. PER-12/PJ/2026, revising PER-11/PJ/2025. Under this regulation, which takes effect from 1 October 2026, the DGT has, among others, amended provisions relating to the amendment of tax returns.

The most significant change is the removal of the delta concept in tax return amendments. Accordingly, tax return amendments performed from 1 October 2026 onwards will transition to the replace scheme (replacement of the tax return).

"To provide ease and legal certainty in the implementation of the fulfilment of obligations related to the amendment of tax reporting through a more effective tax administration system," reads an excerpt from the considering section of PER-12/PJ/2026, as cited on Wednesday (30/9/2026).

In connection with these amendments, the DGT has adjusted provisions concerning the format, contents and procedure for completing tax returns. In addition, the DGT has also introduced 10 new articles, all of which explain what occurs when a tax return is amended.

For example, Article 13A and Article 13B set out provisions on the amendment of periodic Article 21/26 Income Tax returns. Under those articles, tax that has been overremitted and offset is now recorded as an overpayment carry-forward for the Article 21/26 income tax withholding agent.

Where a periodic Article 21/26 Income Tax return is amended or a notice of tax assessment (surat ketetapan pajak/SKP in Indonesian) is issued to amend it, the balance may be adjusted in the next standard periodic tax return without the need to amend the tax returns for the intervening periods.

In addition to Article 13A and Article 13B, other new articles include Article 29A, Article 29B, Article 29C, Article 29D, Article 29E, Article 80A, Article 129A and Article 129B. Alongside the introduction of new articles, a number of existing articles have also been adjusted.

For information, the delta scheme implies that an amended tax return does not replace or negate the original tax return being amended, thereby, the value of the amended return represents the difference between the amended return and the original return.

The replace scheme, on the other hand, implies that the amended tax return fully supersedes the original return being amended, such that the figure shown represents the full value of the new tax return. Previously, the replace scheme could only be used in very limited circumstances.

The DGT hopes that the issuance of PER-12/PJ/2026 will facilitate taxpayers in fulfilling their obligations. This is because the system will now compare the result of the amended tax return against amounts that the taxpayer has actually paid or that have already been refunded. (rig)