PER-6/PJ/2026 Issued: Timeline for Global Minimum Tax Reporting

JAKARTA, DDTCNews - The Directorate General of Taxes (DGT) has outlined the global minimum tax (GMT) reporting timeline. One item on the timeline is the deadline for registration for GloBE taxpayer status. This topic is one of the reviews in national media today, Friday (22/5/2026).

DGT has reminded entities that are members of multinational enterprise (MNE) groups covered by the Global Anti-Base Erosion Rules (GloBE) to apply for status addition as GloBE taxpayers.

"Registration must be completed no later than 30 September 2026. Why must they register? Because there are criteria to be fulfilled," said DGT Director of International Taxation, Dwi Astuti, at the Kompak seminar organised by the Tax Training Centre (Pusdiklat Pajak) and the Faculty of Economics and Business, Gadjah Mada University (FEB UGM).

Pursuant to the Director General of Taxes Reg. No. PER-6/PJ/2026, this application must be submitted by GloBE taxpayers no later than 9 months after the first year of the imposition of GloBE ends.

As set out in Article 3 paragraph (1) of PER-6/PJ/2026, registration is required for constituent entities or members of joint venture groups of MNE groups with revenue of a minimum of EUR750 million based on the ultimate parent entity's consolidated financial statements in 2 of the 4 years preceding the year of the imposition of GloBE.

If the first year of the imposition of GloBE is 2025, the application for status addition must be submitted by the MNE group entity member no later than 30 September 2026.

After registering as a GloBE taxpayer, the top-up tax in relation to GloBE must be settled by year-end, i.e., 31 December 2026.

After making the payment, GloBE taxpayers must also file an Annual Income Tax Return in the context of implementing GloBE, a GloBE Information Return (GIR) or a notification no later than 30 June 2027.

According to Dwi, the global minimum tax will serve as a solution for developing countries in securing their taxing rights amid an increasingly uncertain global landscape.

"After all, 75% of our state budget originates from taxes. In the current situation, where the global economy is uncertain, taxes remain the mainstay," said Dwi.

In addition to the above topic, there are reviews on the potential additional revenue from the global minimum tax. There is also a discussion on transfer pricing abuse, annual tax return filing realisation, SDA exports via Danantara and other topics.

The following is a full review of the tax articles.

Challenges of Implementing Global Minimum Tax

DDTC Fiscal Research & Advisory (FRA) Senior Partner B. Bawono Kristiaji has outlined 7 challenges that tax authorities and taxpayers must navigate in implementing the global minimum tax.

One of those challenges is that the global anti-base erosion (GloBE) rules are not a static regime. The regime evolves dynamically in line with the latest global economic and political developments.

"If we study the global minimum tax, it is not a finished product. It is something that has new developments every year," said Bawono. (DDTCNews)

Transfer Pricing Abuse in Natural Resource Exports

Minister of Finance, Purbaya Yudhi Sadewa, has cited numerous cases of transfer pricing manipulation in transactions conducted between related parties, particularly in natural resource (sumber daya alam/SDA in Indonesian) exports.

Purbaya said the National Single Window Institution (Lembaga National Single Window/LNSW in Indonesian) found transfer pricing abuse in SDA exports by CPO exporters, with a tendency to sell commodities to Singapore subsidiaries before reaching the final destination.

"There is transfer pricing where the price from here to there is overstated, but the one in Indonesia is stated as a loss. The income statement in Indonesia indicates a loss, very low. So I also lose Income Tax here, I lose a lot," he said. (DDTCNews/Kontan)

Oil and Gas Commodities Excluded from Mandatory Export via Danantara

The government has excluded the upstream oil and gas sector from the obligation to export SDA commodities via the SOE designated as the single exporter.

The obligation to export SDA commodities via an SOE will be stipulated under a Government Regulation on SDA Commodity Export Governance. According to the Minister of Energy and Mineral Resources, Bahlil Lahadalia, the government has decided to exclude the upstream oil and gas sector from the provisions of that government regulation.

"The President has decided that government regulation does not apply to the upstream oil and gas sector. So, there is no such obligation. There is no need for doubt,” said Bahlil. (DDTCNews/Kontan)

Annual Tax Return Filing Realisation as of 20 May 2026

The DGT has received a total of 13.32 million Annual Income Tax Returns for 2025 as of 20 May 2026.

This number consists of 12.36 million individual tax returns and 958,240 corporate returns. The proportion of returns filed by corporate taxpayers accounts for approximately 7.19% of the total annual tax returns received by DGT.

"The filing of annual income tax returns for the period up to 20 May 2026 stands at 13.32 million returns," said the DGT Director of Tax Dissemination, Service and Public Relations, Inge Diana Rismawanti. (DDTCNews)

Potential Additional Revenue from Global Minimum Tax

DGT estimates the potential additional state revenue from the global minimum tax (GMT) implementation reaches IDR4.49 trillion. This additional revenue derives from three main mechanisms that Indonesia is beginning to adopt.

Director General of Taxes, Bimo Wijayanto, said approximately 722 business groups are affected by GMT implementation. Of these, 46 MNE groups fulfil the requirements for GMT reporting obligations based on country-by-country reporting (CbCR) data for 2021 to 2024.

Bimo detailed that the potential additional revenue from GMT derives from several main mechanisms. Under the Qualified Domestic Minimum Top-Up Tax (QDMTT) scheme, potential revenue is estimated to reach IDR86.38 billion from three company groups.

Meanwhile, the largest contribution is expected to come from the Income Inclusion Rule (IIR) mechanism, amounting to IDR4.41 trillion from four MNE groups. For the Under-Taxed Profits Rule (UTPR) scheme, DGT will calculate the potential separately. (DDTCNews/Kontan)

EV Industry Not Yet Mature: Plans to Impose Tax Advised to Be Postponed

The Institute for Development of Economics and Finance (INDEF) believes the government should not rush to impose an electric vehicle (EV) tax in regions before the national EV population reaches a more mature level.

Head of Industrial and Transport Decarbonisation of the INDEF Green Transition Initiative (GTI), Andry Satrio Nugroho, said EV incentives are still needed to maintain the energy transition momentum and reduce Indonesia's dependence on fuel imports.

“Insofar as the EV population has not exceeded or at least approached 50% of total vehicles, incentives still need to be provided continuously,” he said. (Kontan)