DGT Maps Tax Disputes; Nexus Assessment Most Dominant
JAKARTA, DDTCNews - The Directorate General of Taxes (DGT) has recorded that the majority of tax disputes between taxpayers and tax authorities in recent years continue to revolve around issues of nexus assessment. This topic is among the reviews featured in national media today, Friday (6/11/2026).
Director General of Taxes, Bimo Wijayanto, stated that out of a total of 39,537 disputes at the Tax Court between 2021 and Q3/2026, as many as 10,117 disputes, or 25.59%, were related to audit methods and techniques, including equalisation and reconciliation techniques.
"The primary category is methods and techniques for nexus assessment. This requires methodology to scrutinise bookkeeping, supporting evidence for the bookkeeping, technical bookkeeping, accounting standards and reconciliation from accounting to taxation. That is the majority," he said.
Further, disputes arising from income or supplies that were not reported, under-reported or incorrectly reported accounted for 17.29% of total disputes.
Meanwhile, disputes arising from income or supplies that were not reported, under-reported or incorrectly reported due to differences in legal interpretation contributed 11.75% of total disputes.
Bimo explained that 9.95% of disputes also arose from the crediting of input VAT that did not fulfil formal or substantive requirements. These disputes arose primarily because the input VAT had no direct connection to business activities as referred to in Article 9 paragraph (8) of the VAT Law.
"There are indeed many such motives, not only in the administrative sphere. If mens rea is proven, that falls within the domain of tax crime," said Bimo.
Further, 8.3% of disputes at the tax court arose from differences of opinion regarding transfer pricing and secondary adjustments.
On another note, disputes between taxpayers and DGT arise from dissenting opinions regarding tax assessments. Before bringing a dispute to the tax court, a taxpayer must first file an objection with the DGT.
An objection may be filed against a notice of tax assessment (surat ketetapan pajak/SKP) or against the withholding or collection of tax by a third party.
If a taxpayer disagrees with an objection decision letter issued by DGT, the taxpayer may file an appeal to the tax court within a maximum of three months from the date the objection decision letter is received.
In addition to the above topic, there are reviews concerning the tax holiday and plans to revise MoF Reg. 69/2024. There are also discussions relating to the findings of the Audit Board (BPK) and their connection to tax overpayments, as well as discussions on personal tax relief, among other matters.
The following are reviews of other taxation articles.
Indonesia–Singapore Joint Task Force: Transfer Pricing & Misinvoicing
The governments of Indonesia and Singapore have agreed to establish a joint task force to address a number of cross-border issues, including transfer pricing and misinvoicing practices that could potentially erode Indonesia's tax revenue.
Director General of Taxes, Bimo Wijayanto, views the cooperation between Indonesia and Singapore as highly important given the practice of shifting profits earned by companies operating in Indonesia to jurisdictions with lower tax rates.
"This has become an inter-state issue. The language used is that of tax fairness, fair tax competition. All countries already understand this; we must address it together," he said. (Bisnis Indonesia)
Government to Retain Tax Holiday; MoF Reg. 69/2024 Set for Revision
The government plans to continue providing tax holiday incentives amid the implementation of the global minimum tax (GMT). To continue offering tax holiday incentives, MoF Reg. 69/2024 will be revised.
This plan was announced by Coordinating Minister for Economic Affairs, Airlangga Hartarto. According to him, providing tax facilities such as the tax holiday is one of the efforts to attract foreign investment to Indonesia.
"Given the current global situation, it appears that several countries will also be reviewing matters related to the GMT. For Indonesia, we will continue to provide facilities, including the tax holiday, to attract investment," he said. (DDTCNews)
DGT Reveals BPK Findings as Reason for Accelerated Refund Revision
The DGT has stated that the revision of the accelerated tax refund provisions set out in Minister of Finance Regulation (MoF Reg.) 28/2026 was prompted by findings of the Audit Board (Badan Pemeriksa Keuangan/BPK in Indonesian).
The Director of Tax Dissemination, Service and Public Relations at the DGT, Inge Diana Rismawanti, said that the BPK's audit findings revealed that accelerated tax refunds had been granted to high-risk taxpayers. The revision of the accelerated tax refund provisions was therefore necessary to address those findings.
"From the BPK audit, it became apparent that this preliminary refund process was, in fact, frequently granted to those who posed a high compliance risk as taxpayers. That is why MoF Reg. 28/2026 was issued," she claimed. (DDTCNews)
Gov't Deliberating Personal Tax Relief Rise, When Will It Take Effect?
Coordinating Minister for Economic Affairs, Airlangga Hartarto, has stated that the planned increase in the personal tax relief (penghasilan tidak kena pajak/PTKP in Indonesian) threshold will not be implemented immediately at the start of the year. This is because the government is still deliberating the new personal tax relief threshold.
Given that discussions on the personal tax relief are ongoing, he has not been able to confirm when the increased personal tax relief will take effect. With only 2 months remaining until the new year, he affirmed that the change to the personal tax relief threshold will not be implemented in January 2027.
"So the discussions have not yet concluded, and this [personal tax relief rise] will not be implemented in January. Perhaps after January we will put it into effect," he said. (DDTCNews/Kontan)
Luxury Homes in IIFC Exempt from STLGs and Article 22 Income Tax
Through Law 6/2026, the government has also prepared sales tax on luxury goods (STLGs) incentives for the Indonesia International Financial Centre (IIFC). These provisions will be regulated further in a minister of finance regulation.
The facilities granted take the form of an exemption from the imposition of STLGs. This exemption applies to the transfer of a group of luxurious residences to individuals, entities, and/or ministries/institutions that conduct business, carry out duties, are domiciled or have a place of residence in the IIFC.
In addition, buyers of residential properties or houses classified as ultra-luxury in the IIFC are also exempt from the collection of Article 22 Income Tax. This is as stipulated under Article 54 paragraph (2) of Law 6/2026. (DDTCNews)
Q3/2026 Economic Growth Reaches 5.47%
Statistics Indonesia (Badan Pusat Statistik/BPS in Indonesian) has announced that Indonesia's economic growth reached 5.47% in Q3/2026 (year on year/yoy).
This figure is lower compared to the growth recorded in Q1/2026 of 5.61%. However, this economic growth figure is significantly higher than the Q2/2026 achievement of 5.29% and the Q3/2025 figure of 5.04%.
"Indonesia's economic growth in Q3/2026 compared with Q3/2025, or on a year-on-year basis, grew by 5.47%," said Deputy Head of the Balance Sheet and Statistical Analysis Division at BPS, Edy Mahmud. (DDTCNews/Kontan)