Guidelines for the Granting of Government Agency Identification Numbers and Tax Filing Obligations

s Denny Vissaro
s Hamida Amri Safarina
By Denny Vissaro, Hamida Amri Safarina
Denny Vissaro
Hamida Amri Safarina
The Director General of Taxes has issued an implementing regulation concerning the guidelines for the granting and use of identification numbers for government agencies and their tax reporting obligations. The policy is stated in Circular No. SE-41/PJ/2021 concerning Implementation Guidelines for the Granting and Use of Identification Numbers for Organization Sub-Units of Government Agencies and Tax Filing Obligations of Government Agencies (SE-41/2021).
 
This regulation has been enacted to provide guidelines in the issuance of identification numbers for organization sub-units of government agencies as well as the exercise of their taxation rights and obligations. Therefore, there is uniformity in the implementation.
 
The Director General of Taxes may issue Taxpayer Identification Numbers (TIN) (Nomor Pokok Wajib Pajak/NPWP) for government agencies based on applications submitted to the Tax Office (Kantor Pelayanan Pajak/KPP) or the Tax Services, Dissemination, and Consultation Office (Kantor Pelayanan, Penyuluhan, dan Konsultasi Perpajakan/KP2KP). In this case, the Head of KPP or KP2KP issues TIN for three government agencies as follows.
  1. Central government agencies. TINs for central government agencies are issued to work units as users of the State Budget and work units that apply the Financial Management Pattern of Public Service Agency (Pola Pengelolaan Keuangan Badan Layanan Umum/PPK-BLU).
  2. Local government agencies. TINs for local government agencies are issued to Local Government Work Units (Satuan Kerja Perangkat Daerah/SKPD) as users of the Regional Budget and work units that implement the Financial Management Pattern of Local Public Service Agency (Pola Pengelolaan Keuangan Badan Layanan Umum Daerah/PPK BLUD).
  3. Village government agencies. TINs for village government agencies are issued to village government organizational units as users of the Village Budget.
The government agencies subject to TIN issuance are obliged to carry out accounting and prepare financial statements of government accounting standards. If the work units/BLU, SKPD/BLUD, and village government organizational units do not carry out accounting and prepare financial statements as per accounting standards, government agency TINs shall not be issued. KPP or KP2KP must continue to verify the applications for TIN registration for government agencies by taking into account the terms and conditions.
 
This regulation also stipulates that government agencies may authorize implementing units under these agencies to take measures and be accountable for state budget revenues and expenditures.
 
On another note, government agencies may appoint organizational subunits to assist in the exercise and/or fulfillment of certain tax obligations. Organizational subunits that assist in the exercise of tax rights and obligations must be registered in the e-Bupot application for government agencies.
 
After the registration, the Directorate General of Taxes (DGT) will issue TINs for the organizational subunits. Next, the organizational subunits registered by government agencies will be automatically given a certificate of registration as organizational subunits through the e-bupot application for government agencies.
 
The organizational subunits will obtain a username and password to access the e-bupot application for government agencies and carry out their tax rights and obligations. There are several tax rights and obligations of organizational subunits as follows:
  1. tax withholding and/or collection;
  2. electronic issuance and/or cancellation of tax withholding and/or collection receipts;
  3. recording of tax invoice data received from partners and tax payment slips (Surat Setoran Pajak/SSP) for the collection of Value Added Tax (VAT) and Sales Tax on Luxury Goods (STLGs) (Pajak Penjualan atas Barang Mewah/PPnBM);
  4. generating billing codes and tax payment or remittance transactions through tax payment banks/ post offices;
  5. applying for overbooking for errors in tax payment error or remittance by the subunit of the remitting organization; and/or
  6. the exercise of tax rights and/or fulfillment of other tax obligations as stipulated by the DGT and carried out electronically.
Tax rights and obligations, in addition to applying for overbooking, are exercised through the e-bupot application for government agencies. In the event that the e-bupot application for government agencies is not yet available, the exercise of tax rights and/or fulfillment of tax obligations of the organizational subunits, in addition to applying for overbooking, are carried out by these government agencies as per applicable regulations.
 
TINs are used for the exercise of tax rights and/or fulfillment of tax obligations of government agencies and treasurers for the July 2020 taxable period to August 2021 taxable period as per the provisions of Article 6 paragraph (3) subparagraph a, subparagraph b, and subparagraph c of the Director General of Taxes Regulation Number PER-13/PJ/2021 concerning Amendments to the Director General of Taxes Regulation Number PER-02/PJ/2021 concerning Procedures for the Granting and Use of Identification Numbers for Organizational Subunits of Government Agencies and Tax Filing Obligations of Government Agencies (PER-13/2021).
 
On another note, tax obligations in the form of tax withholding and/or collection, remittance, and filing for the July 2020 taxable period to August 2021 taxable period are also fulfilled as per the provisions of Article 8 paragraph (1), paragraph (2), and paragraph (3) of PER-13/2021.
 
It should be understood that the Director General of Taxes has ex officio nullified treasurer TINs as of 1 September 2021. Thus, the exercise of tax rights and/or fulfillment of tax obligations since the September 2021 taxable period only use government agency TINs.
 
In addition, this regulation stipulates the monitoring and socialization of the registration of organizational subunits and/or the exercise of tax rights and/or fulfillment of tax obligations. This circular was enacted on 27 July 2021.