Provisions on Tax Audits during the Transitional Period of Changes to Tax Office Types

s Deborah
s Puput Bayu Wibowo
By Deborah, Puput Bayu Wibowo
Deborah
Puput Bayu Wibowo
The tax authorities postpone the time of registration (Saat Mulai Terdaftar/SMT) for taxpayers registered or confirmed as Taxable Persons for VAT Purposes (Pengusaha Kena Pajak/PKP) at the new Small Tax Offices (Kantor Pelayanan Pajak/KPP) or Medium Tax Offices from 3 May 2021 to 24 May 2021.
 
In light of the postponement of SMT, the authorities also revise the provisions on tax audits carried out during the transitional period of changes to KPP types from Small Tax Offices to Medium Tax Offices as part of the Directorate General of Taxes’ (DGT) vertical unit reorganization.
 
The SMT postponement and the amendment to the provisions on tax audits are outlined in the Director General of Taxes Regulation No. PER-09/PJ/2021 concerning Amendments to the Director General of Taxes Regulation No. PER-06/PJ/2021 concerning Administrative Procedures for the Transfer of Taxpayers’ Places of Registration and/or Places of Business Reporting for Taxable Persons for VAT Purposes in the Context of Reorganization of the Directorate General of Taxes’ Vertical Agencies (PER-09/2021).
 
The changes listed in PER-09/2021 are aimed at adjusting to the postponement of the implementation time of the organization, work procedures, and the start of operation of the DGT’s vertical agencies affected by the reorganization, from 3 May 2021 to 24 May 2021.
 
In further detail, PER-09/PJ/2021 specifies that the following six provisions apply to audits carried out by the old Small Tax Offices subject to changes in the type of KPP:
 
First, routine audits other than on tax returns of refund overpayment and special audits, the stipulation of which expires on 31 August 2021, shall be completed by the old Small Tax Office no later than 7 May 2021.
 
Second, routine audits other than on tax returns of refund overpayment and special audits, the stipulation of which expires after 31 August 2021, the following provisions shall apply:
  1. completed by Small Tax Offices no later than 7 May 2021, in the event that the Notification of Tax Audit Findings (Surat Pemberitahuan Hasil Pemeriksaan/SPHP) has been submitted to the taxpayer by 27 April 2021;
  2. transferred to the new Small Tax Office or Medium Tax Office on 3 May 2021, in the event that SPHP has not been submitted to the taxpayer by 19 March 2021;
Third, audits for other purposes on the application for the deletion of Taxpayer Identification Number (Nomor Pokok Wajib Pajak/NPWP) or the revocation of PKP confirmation for which the issuance deadline of the decree falls up to 31 August 2021, shall be completed by the old Small Tax Office no later than 7 May 2021;
 
Fourth, audits for other purposes on the application for the deletion of NPWP or the revocation of PKP confirmation for which the issuance deadline of the decree falls after 31 August 2021, shall be transferred to the new Small Tax Office or Medium Tax Office on 24 May 2021;
 
Fifth, audits for other purposes other than on the application for the deletion of NPWP or the revocation of PKP confirmation for which the application is submitted by 19 March 2021, shall be completed by the old Small Tax Office no later than 7 May 2021; or
 
Sixth, audits for other purposes other than on the application for the deletion of NPWP or the revocation of PKP confirmation for which the application is submitted after 19 March 2021, shall be completed by the new Small Tax Office or Medium Tax Office.
 
Further, the following provisions shall apply to the application for refunds of tax overpayments based on Article 17B of the General Tax Provisions and Procedures Law Law implemented by the old Small Tax Offices subject to changes in the type of KPP:
  1. requests for refunds of which the issuance deadline of the Notice of Tax Assessment falls up to 31 August 31, the old Small Tax Office shall complete the audits by 7 May 2021 and issue a Notice of Tax Assessment (Surat Ketetapan Pajak/SKP) and/or Notice of Tax Collection (Surat Tagihan Pajak/STP) pursuant to statutory provisions in the taxation sector;
  2. requests for refunds of which the issuance deadline of the Notice of Tax Assessment falls after 31 August 2021:
    1. shall be completed by the old Small Tax Office no later than 7 May 2021, in the event that SPHP has been submitted to taxpayers by 27 April 2021, and the new Small Tax Office or Medium Tax Office issues SKP and/or STP pursuant to statutory provisions in the taxation sector; or
    2. shall be transferred to the new Small Tax Office or Medium Tax Office on 24 May 2021, in the event that SPHP has not been submitted to taxpayers by 27 April 2021.