Changes in Duties, Responsibilities, Requirements, and Number of Account Representatives at Tax Offices

s Puput Bayu Wibowo
s Fakry
By Puput Bayu Wibowo, Fakry
Puput Bayu Wibowo
The Ministry of Finance amends the duties, responsibilities, requirements, and number of account representatives (AR) at Tax Offices (Kantor Pelayanan Pajak/KPP). The Ministry of Finance renders these changes to adapt to the organizational arrangements and working procedures of the DGT’s vertical agencies.
Changes in duties, responsibilities, requirements, and the number of AR are outlined in the Minister of Finance Regulation No. 45/PMK.01/2021 concerning Account Representatives at Tax Offices (MoF Reg. 45/2021). On another note, these changes are intended to improve the effectiveness and optimize the implementation of AR tasks at KPP.
Promulgated on 5 May 2021, MoF Reg. 45/2021 has taken effect thereafter. The enactment of MoF Reg. 45/2021 simultaneously revokes the Minister of Finance Regulation No. 79/PMK.01/2015 concerning Account Representatives at Tax Offices (MoF Reg. 79/2015).
AR refers to an executive position at KPP with several levels of positions pursuant to statutory provisions. In further detail, through MoF Reg. 45/2021, the DGT stipulates seven tasks for AR to carry out, including:
  1. analyzing, elaborating, to ensure that taxpayers and tax management comply with taxation statutory provisions through planning, implementation, and follow-up of intensification and extensification based on data collection and mapping of tax subjects and objects;
  2. performing territorial control, observing tax potentials, and controlling information;
  3. searching, collecting, processing, researching, analyzing, updating, and following-up on tax data;
  4. performing taxation control of taxpayers;
  5. drafting appeals and performing counseling to taxpayers;
  6. performing supervision and follow-up monitoring of data and information including but not limited to tax returns, third party data, and tax amnesty data;
  7. carrying out administrative management of stipulations and drafting the concept of legal product issuance and tax control products.
In carrying out the seven tasks, an AR is responsible to the supervising officer as his direct supervisor. The tasks set out under MoF Reg. 45/2021 differ from those set out under MoF Reg. 79/2015.
Formerly, pursuant to MoF Reg. 79/2015, AR was divided into two types, including: (i) AR that carries out taxpayer service and consulting function; and (ii) AR that supervises and explores taxpayers’ potential. The two types of AR carry out different tasks, as listed in Table 1.
Table 1 Job Description of AR Based on MoF Reg. 79/2015Source: MoF Reg. 79/2015.
MoF Reg. 45/2021 also states that the division of taxpayers or working areas that constitutes the scope of AR’s duties and their number is stipulated by the Head of KPP. The Head of KPP determines the number of AR as per the availability of the DGT’s employees, workload, and potential tax revenues at the relevant KPP. AR shall be appointed and dismissed by the Director General of Taxes pursuant to statutory provisions.
Further, MoF Reg. 45/2021 stipulates the positions and job ranks of AR referring to the Minister of Finance Decree concerning positions and job ranks for executors within the Ministry of Finance. Within the KPP, the positions and job ranks are stipulated by small leaders who administratively oversee said KPP and on behalf of medium leaders.
In addition to revising tasks, MoF Reg. 45/2021 also amends the requirements for DGT employees to be appointed as AR. Referring to Article 6 paragraph (1) of MoF Reg. 45/2021, four conditions are to be met for DGT employees to be appointed as AR.
First, having a Civil Servant (Pegawai Negeri Sipil/PNS) status. Second, having worked for a minimum of 2 years. Third, minimum education level of Diploma III. Fourth, upon proposed appointment, having the lowest rank/rank group of Supervisor (II/c).
There are more requirements than in the previous regulation. Formerly, MoF Reg. 79/2015 only stipulated 2 requirements. First, passing formal education of high school at the minimum. Second, the lowest rank at the time of recommendation is Regulator (Group II/c).
Similar to the previous provisions, however, the appointment as AR must take into account the availability of the DGT’s employees, workload, and potential tax revenues at the relevant Tax Office.
As for employees who have been appointed as AR before the enactment of MoF Reg. 45/2021, they shall remain in office and are recognized as AR. These employees must also carry out their duties as per the provisions under MoF Reg. 45/2021 until said employees are appointed as Tax Auditors or Tax Auditor Assistants or other positions.