Minister of Finance of the Republic of Indonesia Regulation - 18/PMK.03/2021

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MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA REGULATION NUMBER 18/PMK.03/2021 CONCERNING THE IMPLEMENTATION OF LAW NUMBER 11 OF 2020 CONCERNING JOB CREATION IN THE FIELD OF INCOME TAX, VALUE ADDED TAX AND SALES TAX ON LUXURY GOODS AS WELL AS GENERAL PROVISIONS AND TAX PROCEDURES BY THE GRACE OF ALMIGHTY GOD THE MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA,

Considering
a.	that to implement the provisions under Article 2 paragraph (4), Article 4 paragraph (1d) and Article 4 paragraph (3) subparagraph f, subparagraph o and subparagraph p of Law Number 7 of 1983 concerning Income Tax as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation, it is necessary to further regulate the provisions in the field of Income Tax to support ease of doing business;
b.	that to implement the provisions under Article 9 paragraph (13) subparagraph a, subparagraph b, subparagraph c and subparagraph e as well as Article 13 paragraph (5a) and paragraph (8) of Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation, it is necessary to regulate the provisions on Value Added Tax and Sales Tax on Luxury Goods to support ease of doing business;
c.	that to implement the provisions under Article 9 paragraph (3a), Article 9 paragraph (4), Article 13 paragraph (6), Article 14 paragraph (6), Article 15 paragraph (5), Article 17B paragraph (1a), Article 27B paragraph (8) and Article 44B paragraph (3) of Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation, it is necessary to regulate the provisions on general provisions and tax procedures to support ease of doing business;
d.	that based on the considerations referred to in letter a, letter b and letter c, it is necessary to enact a Minister of Finance Regulation concerning the Implementation of Law Number 11 of 2020 concerning Job Creation in the Field of Income Tax, Value Added Tax and Sales Tax on Luxury Goods as well as General Provisions and Tax Procedures;

In view of
1.	Article 17 paragraph (3) of the 1945 Constitution of the Republic of Indonesia;
2.	Law Number 6 of 1983 concerning General Provisions and Tax Procedures Regulations (State Gazette of the Republic of Indonesia of 1983 Number 49, Supplement to the State Gazette of the Republic of Indonesia Number 3262) as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation (State Gazette of the Republic of Indonesia of 2020 Number 245, Supplement to the State Gazette of the Republic of Indonesia Number 6573);
3.	Law Number 7 of 1983 concerning Income Tax (State Gazette of the Republic of Indonesia of 1983 Number 50, Supplement to the State Gazette of the Republic of Indonesia Number 3263) as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation (State Gazette of the Republic of Indonesia of 2020 Number 245, Supplement to the State Gazette of the Republic of Indonesia Number 6573);
4.	Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods (State Gazette of the Republic of Indonesia of 1983 Number 51, Supplement to the State Gazette of the Republic of Indonesia Number 3264) as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation (State Gazette of the Republic of Indonesia of 2020 Number 245, Supplement to the State Gazette of the Republic of Indonesia Number 6573);
5.	Law Number 39 of 2008 concerning State Ministries (State Gazette of the Republic of Indonesia of 2008 Number 166, Supplement to the State Gazette of the Republic of Indonesia Number 4916);
6.	Law Number 11 of 2020 concerning Job Creation (State Gazette of the Republic of Indonesia of 2020 Number 245, Supplement to the State Gazette of the Republic of Indonesia Number 6573);
7.	Presidential Regulation Number 57 of 2020 concerning the Ministry of Finance (State Gazette of the Republic of Indonesia of 2020 Number 98);
8.	Minister of Finance Regulation Number 145/PMK.03/2012 concerning Procedures for the Issuance of Notice of Tax Assessment and Notice of Tax Collection (Official Gazette of the Republic of Indonesia of 2012 Number 902) as amended by the Minister of Finance Regulation Number 183/PMK.03/2015 concerning the Amendment to Minister of Finance Regulation Number 145/PMK.03/2012 concerning Procedures for the Issuance of Notice of Tax Assessment and Notice of Tax Collection (Official Gazette of the Republic of Indonesia of 2015 Number 1467);
9.	Minister of Finance Regulation Number 17/PMK.03/2013 concerning Procedures for Audits (Official Gazette of the Republic of Indonesia of 2013 Number 47) as amended by the Minister of Finance Regulation Number 184/PMK.03/2015 concerning the Amendment to Minister of Finance Regulation Number 17/PMK.03/2013 concerning Procedures for Audits (Official Gazette of the Republic of Indonesia of 2015 Number 1468);
10.	Minister of Finance Regulation Number 239/PMK.03/2014 concerning Procedures for Preliminary Audits of Tax Crimes (Official Gazette of the Republic of Indonesia of 2014 Number 1951);
11.	Minister of Finance Regulation Number 242/PMK.03/2014 concerning Procedures for the Payment and Remittance of Taxes (Official Gazette of the Republic of Indonesia of 2014 Number 1973);
12.	Minister of Finance Regulation Number 243/PMK.03/2014 concerning Tax Returns (Official Gazette of the Republic of Indonesia of 2014 Number 1974) as amended by the Minister of Finance Regulation Number 9/PMK.03/2018 concerning the Amendment to Minister of Finance Regulation Number 243/PMK.03/2014 concerning Tax Returns (Official Gazette of the Republic of Indonesia of 2018 Number 180);
13.	Minister of Finance Regulation Number 55/PMK.03/2016 concerning Applications for the Termination of Tax Crime Investigations for Tax Revenue Purposes (Official Gazette of the Republic of Indonesia of 2016 Number 538);
14.	Minister of Finance Regulation Number 217/PMK.01/2018 concerning the Organisation and Work Procedures of the Ministry of Finance (Official Gazette of the Republic of Indonesia of 2018 Number 1862) as amended several times, last amended by Minister of Finance Regulation Number 229/PMK.01/2019 concerning the Second Amendment to the Minister of Finance Regulation Number 217/PMK.01/2018 concerning the Organisation and Work Procedures of the Ministry of Finance (Official Gazette of the Republic of Indonesia of 2019 Number 1745);

HAS DECIDED:
To enact
MINISTER OF FINANCE REGULATION CONCERNING THE IMPLEMENTATION OF LAW NUMBER 11 of 2020 CONCERNING JOB CREATION IN THE FIELD OF INCOME TAX, VALUE ADDED TAX AND SALES TAX ON LUXURY GOODS AS WELL AS GENERAL PROVISIONS AND TAX PROCEDURES.

CHAPTER I GENERAL PROVISIONS Article 1
Referred to herein this Minister of Finance Regulation:
1.	Income Tax Law, hereinafter referred to as the PPh Law, is Law Number 7 of 1983 concerning Income Tax as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
2.	Value Added Law, hereinafter referred to as the VAT Law, is Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
3.	General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
4.	Income Tax, hereinafter abbreviated to PPh, is Income Tax referred to in the Income Tax Law.
5.	Value Added Tax, hereinafter abbreviated to VAT, is Value Added Tax referred to in the VAT Law.
6.	Sales Tax on Luxury Goods, hereinafter abbreviated to STLGs, is Sales Tax on Luxury Goods referred to in the VAT Law.
7.	Land and Building Tax, hereinafter abbreviated to PBB, is Land and Building Tax referred to in Law Number 12 of 1985 concerning Land and Building Tax as amended by Law Number 12 of 1994.
8.	Taxpayer is any individual or entity, comprising a taxpayer, a withholding agent and a collecting agent having tax rights and obligations pursuant to statutory tax provisions.
9.	Tax Year is a period of 1 (one) calendar year unless a Taxpayer adopts an accounting year that is different from the calendar year.
10.	Taxable Period is a period used as the basis for a Taxpayer to calculate, remit and file taxes payable in a certain period as stipulated by the General Provisions and Tax Procedures Law.
11.	Taxpayer Identification Number, hereinafter abbreviated to TIN, is a number issued to Taxpayers as a means of tax administration that is used as a personal identity or Taxpayer identity in conducting their tax rights and obligations.
12.	State Revenue Transaction Number, hereinafter abbreviated to NTPN, is the number of receipt of payment or remittance to the state treasury issued through the state revenue module or by the state revenue system managed by the Directorate General of Treasury.
13.	Indonesian Citizen, hereinafter abbreviated to WNI, is a native Indonesian person or a person of another nationality who has been legalised as an Indonesian Citizen pursuant to statutory provisions on the citizenship of the Republic of Indonesia.
14.	Foreign National, hereinafter abbreviated to WNA, is anyone who is not an Indonesian Citizen.
15.	Certificate of Indonesian Citizens Fulfilling the Requirements to Become Non-Tax Residents is a letter issued by the Head of the Tax Office on behalf of the Director General of Taxes explaining that an Indonesian Citizen fulfils the requirements to be a non-tax resident.
16.	Tax Treaty, hereinafter abbreviated to P3B, is an agreement between the Government of Indonesia and the government of a tax treaty partner to prevent double taxation and tax evasion.
17.	Employer is a legal entity or another entity that employs a Foreign National by paying wages or remunerations in other forms.
18.	Dividend is the surplus received or accrued by shareholders.
19.	Net Income After Tax is comprehensive net income after tax.
20.	Retained Earnings is the accumulation of Net Income After Tax that is not distributed to the shareholders in the form of Dividends which are used to finance various company interests.
21.	Hajj Financial Management Agency, hereinafter abbreviated to BPKH, is an institution that carries out the financial management of hajj pursuant to statutory provisions on the financial management of hajj.
22.	Hajj Fees, hereinafter abbreviated to BPIH, are an amount of funds that must be paid by a citizen who will carry out hajj.
23.	Special Hajj Fees, hereinafter referred to as Special BPIH, are an amount of funds that must be paid by a citizen who will carry out special hajj.
24.	Customs Territory is the territory of the Republic of Indonesia which includes land, waters and airspace above it as well as certain places in the Exclusive Economic Zone and the continental shelf in which the Law that stipulates customs is applicable.
25.	Tax Base is the amount of Selling Price, Considerations, Import Value, Export Value or other values used as the basis for calculating tax payable.
26.	Taxable Goods, hereinafter abbreviated to BKP, are goods subject to tax pursuant to the VAT Law.
27.	Taxable Services, hereinafter abbreviated to JKP, services subject to tax pursuant to the VAT Law.
28.	Entrepreneur is any individual or entity in whatever form that in its course of business or work produces goods, imports goods, exports goods, conducts trading business, utilises intangible goods from outside the Customs Territory, conducts service businesses or utilizes services from outside the Customs Territory.
29.	Taxable Persons, hereinafter abbreviated to PKP, are Entrepreneurs supplying Taxable Goods and/or Taxable Services subject to tax pursuant to the VAT Law.
30.	Taxable Persons that Have Not Performed Any Supply are Taxable Persons that have not performed supplies of Taxable Goods, supplies of Taxable Services, exports of Taxable Goods, and/or exports of Taxable Services.
31.	Tax Office, hereinafter abbreviated to KPP, is an office within the Directorate General of Taxes where Taxpayers are registered, Taxable Persons are registered and/or Land and Building Tax objects are administered.
32.	State Treasury Office, hereinafter abbreviated to KPPN, is a vertical agency of the Directorate General of Treasury that obtains power of attorney from the State General Treasurer to carry out some of the functions of the Proxy of State General Treasurer.
33.	Tax Invoice is collection receipt by Taxable Persons supplying Taxable Goods or Taxable Services.
34.	Input VAT is VAT that should have been paid by Taxable Persons due to an acquisition of Taxable Goods and/or acquisition of Taxable Services and/or utilisation of intangible Taxable Goods from outside the Customs Territory and/or utilisation of Taxable Services from outside the Customs Territory and/or imports of Taxable Goods.
35.	Output VAT is VAT payable which must be collected by Taxable Persons performing supplies of Taxable Goods, supplies of Taxable Services, exports of tangible Taxable Goods, exports of intangible Taxable Goods and/or exports of Taxable Services.
36.	Tax Payment Slip is a receipt of tax payment or remittance using a specific form or other means to the state treasury, through a place of payment appointed by the Minister of Finance.
37.	Electronic Information is one or a set of electronic data, including but not limited to writing, sound, pictures, maps, designs, photographs, electronic data interchange (EDI), electronic mail, telegram, telex, telecopy or the like, letters, signs, numbers, access codes, symbols or processed perforations that have meaning or are comprehensible by people who are able to understand them.
38.	Electronic Signature is a signature consisting of Electronic Information that is attached, associated or related to other Electronic Information which is used as a verification and authentication tool.
39.	Electronic Commerce is a trade in which transactions are carried out through a set of electronic devices and procedures.
40.	Tax Liability is outstanding tax, including administrative penalties in the form of interest, fines or surcharges as stated in the notice of tax assessment or similar letters pursuant to statutory provisions in the field of taxation.
41.	Interest Compensation Decision Letter, hereinafter abbreviated to SKPIB, is a decision letter that determines the amount of interest compensation granted to a Taxpayer.
42.	Calculation of Interest Compensation Decision Letter, hereinafter abbreviated to SKPPIB, is a decision letter used as the basis for calculating interest compensation in an SKPIB against the Tax Liability and/or taxes that will be payable.
43.	Payment Order for Interest Compensation, hereinafter abbreviated to SPMIB, is a letter issued by the Head of the Tax Office on behalf of the Minister of Finance to pay interest compensation to a Taxpayer.
44.	Tax Refund Decision Letter, hereinafter abbreviated to SKPKPP, is a decision letter used as the basis for issuing a Disbursement of Refund Claim.
45.	Fund Disbursement Order, hereinafter abbreviated to SP2D, is a letter issued by the Head of the KPPN as the Proxy of the State General Treasurer to carry out expenditures borne by the State Budget based on the Interest Compensation Payment Orde.
46.	Closing Conference is a discussion between a Taxpayer and tax auditors on audit findings, the results of which are stated in the official report of closing conference, which are signed by both parties and contain corrections to the principal tax payable, either approved or disapproved and the calculation of administrative penalties.
47.	Computer Data Archiving, hereinafter abbreviated to ADK, is data archiving in softcopy form that are stored in digital storage media.

CHAPTER II INCOME TAX Section One Requirements of Individual Tax Subjects Article 2
(1)	An individual constituting a tax resident is an Indonesian Citizen or a Foreign National who:
	a.	resides in Indonesia;
	b.	has been present in Indonesia for more than (one hundred and eighty-three) days within any 12 (twelve) months period; or
	c.	has been residing in Indonesia within a particular Tax Year and intends to reside in Indonesia.
(2)	An individual who resides in Indonesia referred to in paragraph (1) subparagraph a is an individual who:
	a.	resides in a place in Indonesia that:
		1.	is held or can be accessed at any time;
		2.	is owned, rented or available to be used; and
		3.	is not merely a place of transit for the individual;
	b.	has a centre of vital interests in Indonesia that is used by the individual as a centre for personal, social, economic and/or financial activities or affairs in Indonesia; or
	c.	carries out daily habits or activities in Indonesia, including activities that constitute interests or hobbies.
(3)	The period of 183 (one hundred and eighty-three) days referred to in paragraph (1) subparagraph b is determined by calculating the length of time an individual is present in Indonesia within any 12 (twelve) months period, either consecutively or intermittently. in which part of the day is treated as 1 (one) day.
(4)	An individual tax subject is deemed to intend to reside in Indonesia as referred to in paragraph (1) subparagraph c may be proven by documents in the form of:
	a.	Permanent Stay Permit Card (KITAP);
	b.	Limited Stay Visa (VITAS) with a validity period of more than 183 (one hundred and eighty-three) days;
	c.	Limited Stay Permit (ITAS) with a validity period of more than 183 (one hundred and eighty-three) days;
	d.	a contract or agreement to perform work, business or activities in Indonesia for more than 183 (one hundred and eighty-three) days; or
	e.	other documents that may indicate the intention to reside in Indonesia, such as a residential rental agreement for more than 183 (one hundred and eighty-three) days or documents showing the transfer of a family member.

Article 3
(1)	An individual constituting a non-tax resident is:
	a.	an individual who does not reside in Indonesia;
	b.	a Foreign National who has been present in Indonesia for not more than 183 (one hundred and eighty-three) days within any 12 (twelve) months period; or
	c.	an Indonesian Citizen who is outside Indonesia for more than 183 days (one hundred and eighty-three) within any 12 (twelve) months period and fulfills the following requirements:
		1.	permanently residing in a place outside Indonesia that is not a place of transit;
		2.	having a centre of vital interests that shows personal, economic and/or social relations outside Indonesia, which can be proven by:
			a)	a husband or wife, children and/or next of kin residing outside Indonesia;
			b)	the income is sourced overseas; and/or
			c)	being a member of a religious, educational, social and/or community organisation recognised by the state government;
		3.	a place of habitual abode;
		4.	becoming a tax resident of another country or jurisdiction; and/or
		5.	other certain requirements.
(2)	The requirements referred to in paragraph (1) subparagraph c number 1, number 2 and number 3 are fulfilled in stages under the following provisions:
	a.	the requirement of residing in a place outside Indonesia referred to in paragraph (1) subparagraph c number 1 is a requirement that must be fulfilled;
	b.	in the event that the Indonesian Citizen who is outside Indonesia for more than 183 (one hundred and eighty-three) days within any 12 (twelve) months period has fulfilled the requirements referred to in the requirement of the centre of vital interests of subparagraph a, the requirements of the centre of vital interests and a place of habitual abode outside Indonesia referred to in paragraph (1) subparagraph c number 2 and number 3 do not have to be fulfilled insofar as the Indonesian Citizen concerned no longer fulfils the requirements of residing in Indonesia referred to in Article 2 paragraph (2) subparagraph a;
	c.	in the event that the person concerned fulfils the requirement of residing in a place outside Indonesia referred to in paragraph (1) subparagraph c number 1 or residing in Indonesia referred to in Article 2 paragraph (2) subparagraph a, the provisions referred to in subparagraph b do not apply and the fulfilment of the requirements shall be continued based on the requirement of the centre of vital interests referred to in paragraph (1) subparagraph c number 2;
	d.	in the event that the fulfilment of the requirements proceeds as referred to in subparagraph c and the Indonesian Citizen concerned only has a centre of vital interests outside Indonesia as referred to in paragraph (1) subparagraph c number 2, the requirement of the place of habitual abode referred to in paragraph (1) subparagraph c number 3 does not have to be fulfilled; and
	e.	in the event that the person concerned fulfils the requirements of residing and centre of vital interests outside Indonesia as referred to in paragraph (1) subparagraph c number 1 and number 2 and also fulfil the requirements of residing and a centre of vital interests in Indonesia as referred to in Article 2 paragraph (2) subparagraph a and subparagraph b, the provisions referred to in subparagraph d do not apply and the fulfilment of the requirements shall be continued based on the requirements of a place of habitual abode outside Indonesia referred to in paragraph (1) subparagraph c number 3.
(3)	The requirements referred to in paragraph (1) subparagraph c number 4 and number 5 are requirements that must be fulfilled.
(4)	The requirements of tax residency referred to in paragraph (1) subparagraph c number 4 are fulfilled in the event that an Indonesian Citizen becomes a tax resident of another country or jurisdiction which may be proven by a certificate of domicile or other documents showing the tax residency from the tax authorities of the other country or jurisdiction with the following requirements:
	a.	using English;
	b.	at least including information regarding:
		1.	the name of the Indonesian Citizen;
		2.	date of issuance;
		3.	validity period; and
		4.	name and signed or given a sign equivalent to a signature by the competent authority as per the prevalence in the country or jurisdiction concerned; and
	c.	the period referred to in subparagraph b number 3 expires no later than 6 (six) months prior to the application for determination of the tax residency to the Director General of Taxes.
(5)	Other certain requirements referred to in paragraph (1) subparagraph c number 5 are:
	a.	having completed tax obligations on all income received or accrued insofar as the Indonesian Citizen constitutes a tax resident; and
	b.	having obtained a Certificate of Indonesian Citizens Fulfilling the Requirements to Become Non-Tax Residents issued by the Director General of Taxes.

Article 4
(1)	To obtain the certificate referred to in Article 3 paragraph (5) subparagraph b, the Indonesian Citizen referred to in Article 3 paragraph (1) subparagraph c must:
	a.	apply for the determination of tax residency stating that the Indonesian Citizen fulfils the requirements as a non-tax resident referred to in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5) subparagraph a; and
	b.	attach documents that may prove the fulfilment of the requirements referred to in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5) subparagraph a.
(2)	The application referred to in paragraph (1) is submitted by an electronic application through certain channels stipulated by the Director General of Taxes.
(3)	In the event that certain channels referred to in paragraph (2) are not yet available, the application may be submitted in writing:
	a.	in person; or
	b.	by post or a shipping company or courier services with proof of postage, to the Tax Office where the Taxpayer is registered.
(4)	The Head of the Tax Office on behalf of the Director General of Taxes, based on examination results, issues:
	a.	Certificate of Indonesian Citizens Fulfilling the Requirements to Become Non-Tax Residents in the event that the Indonesian Citizen has fulfilled the provisions in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5); or
	b.	a letter of rejection of the application in the event that the Indonesian Citizen does not fulfil the provisions in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5),
	within a maximum period of 30 (thirty) days after the application referred to in paragraph (1) is completely received.
(5)	In the event that the deadline of 30 (thirty) days referred to in paragraph (4) has elapsed and the Head of the Tax Office on behalf of the Director General of Taxes has not made a decision, the Indonesian Citizen’s application is deemed accepted.
(6)	The Head of the Tax Office on behalf of the Director General of Taxes issues the Certificate of Indonesian Citizens Fulfilling the Requirements to Become Non-Tax Residents within a maximum period of 5 (five) days after the deadline referred to in paragraph (4) elapses.
(7)	The provisions on the format of documents in the form of:
	a.	the application referred to in paragraph (1) subparagraph a;
	b.	Certificate of Indonesian Citizens Fulfilling the Requirements to Become Non-Tax Residents referred to in paragraph (4) subparagraph a; and
	c.	the letter of rejection of the application referred to in paragraph (4) subparagraph b, are listed in Appendix I which constitutes an integral part of this Ministerial Regulation.
(8)	In the event that in the future, data and/or information is found that tax obligations have not been or have not been fully fulfilled by the Indonesian Citizen who fulfils the requirements referred to in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5), the Director General of Taxes may issue tax assessments pursuant to statutory provisions in the field of taxation.

Article 5
(1)	The Indonesian Citizen referred to in Article 3 paragraph (1) subparagraph c is treated as an individual leaving Indonesia for good as referred to in Article 2A of the Income Tax Law and becomes a non-tax resident since leaving Indonesia.
(2)	An Indonesian Citizen who at the time of leaving Indonesia can show that he/she has the intention of becoming a non-tax resident pursuant to the provisions under Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5), may apply to be stipulated as a non-effective Taxpayer when leaving Indonesia pursuant to statutory provisions in the field of general provisions and tax procedures.
(3)	The application to be stipulated as a non-effective Taxpayer referred to in paragraph (2) shall be submitted by the Taxpayer through:
	a.	the Tax Office where the Taxpayer is registered;
	b.	the Tax Services, Dissemination and Consultation Service Office located within the working area of the Tax Office where the Taxpayer is registered; or
	c.	certain channels stipulated by the Director General of Taxes.
(4)	The application to be stipulated as a non-effective Taxpayer referred to in paragraph (2) must be proven by attaching supporting documents that can prove the intention referred to in paragraph (2) and the fulfilment of tax obligations.
(5)	The Indonesian Citizen referred to in paragraph (2) must continue to fulfil certain requirements referred to in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5) in the event that he/she has actually been outside Indonesia for more than 183 (one hundred and eighty-three) days within any 12 (twelve) months period by applying as referred to in Article 4 paragraph (1).

Article 6
(1)	The Indonesian Citizen referred to in Article 3 paragraph (1) subparagraph c and Article 5 paragraph (2) who does not receive or accrue income sourced from Indonesia are not subject to Income Tax in Indonesia.
(2)	In the event that the Indonesian Citizen referred to in paragraph (1) receives or accrues income sourced from Indonesia, such income is subject to Income Tax pursuant to statutory provisions in the field of taxation applicable to non-tax residents.
(3)	In the event that the Indonesian Citizen referred to in Article 5 paragraph (2) in the further is actually known to not fulfil the requirements as a non-tax resident as referred to in Article 3 paragraph (1) subparagraph c, paragraph (2), paragraph (3), paragraph (4) and paragraph (5) or does not implement the provisions referred to in Article 5 paragraph (5), the said Indonesian Citizen:
	a.	the stipulation as a non-effective Taxpayer becomes nullified;
	b.	remains as a tax resident; and
	c.	is subject to taxes pursuant to statutory provisions in the field of taxation applicable to tax residents.
(4)	In the event that the Indonesian Citizen referred to in paragraph (3) is subject to the withholding of Article 26 Income Tax of the Income Tax Law from the determination as a non-effective Taxpayer until the nullification as a non-effective Taxpayer, the said Article 26 Income Tax is creditable in calculating tax payable for Tax Year concerned.

Section Two Certain Skill Criteria and Procedures for the Imposition of Income Tax for Foreign Nationals Article 7
(1)	The income stipulated under Article 4 paragraph (1) of the Income Tax Law, either sourced from Indonesia or overseas, is subject to Income Tax pursuant to statutory provisions in the field of Income Tax.
(2)	Excluded from the provisions referred to in paragraph (1), a Foreign National who constitutes a tax resident as referred to in Article 2 is subject to Income Tax only on income received or accrued from Indonesia under the following conditions:
	a.	having certain skills; and
	b.	valid for 4 (four) Tax Years since he/she becomes a tax resident.
(3)	Included in the definition of income received or accrued from Indonesia referred to in paragraph (2) is income received or accrued by a Foreign National in connection with work, services or activities in Indonesia in whatever name and form paid outside Indonesia.
(4)	The provisions referred to in paragraph (2) do not apply to a Foreign National taking advantage of a Tax Treaty between the Government of Indonesia and the government of the Tax Treaty partner where the Foreign National earns income overseas.

Article 8
(1)	Foreign Nationals with certain skills referred to in Article 7 paragraph (2) subparagraph a include foreign workers occupying certain positions and foreign researchers.
(2)	Foreign Nationals with certain skills referred to in paragraph (1) employed by the Employer, must fulfil the requirements concerning:
	a.	the employment of foreign workers who may occupy certain positions as stipulated by the minister in charge of governmental affairs in the field of manpower; or
	b.	foreign researchers appointed by the minister in charge of governmental affairs in the field of research.
(3)	Certain skill criteria referred to in paragraph (1) include:
	a.	foreign nationality;
	b.	having expertise in the fields of science, technology and/or mathematics, as evidenced by:
		1.	certificate of expertise issued by an institution appointed by the Government of Indonesia or the government of the foreign worker’s country of origin;
		2.	education diploma; and/or
		3.	5 (five) years of work experience at the minimum,
		in the field of science or field of work as per the field of expertise; and
	c.	having the obligation to transfer knowledge.
(4)	The provisions on certain positions referred to in paragraph (1) are listed in Appendix II which constitutes an integral part of this Ministerial Regulation.

Article 9
(1)	The period of 4 (four) Tax Years referred to in Article 7 paragraph (2) subparagraph b is calculated from the time a Foreign National becomes a tax resident.
(2)	If within this period of 4 (four) Tax Years referred to in paragraph (1), the Foreign National leaves Indonesia, the end of that period continues to be calculated from the time the Foreign National first constitutes a tax resident.

Article 10
A Foreign National may choose to be subject to Income Tax only on income received or accrued in Indonesia or take advantage of the Tax Treaty between the Government of Indonesia and the government of the tax treaty partner where the Foreign National derives income overseas.

Article 11
(1)	A Foreign National who chooses to be subject to Income Tax only on income received or accrued from Indonesia as referred to in Article 7 paragraph (2) must apply to the Director General of Taxes.
(2)	The application referred to in paragraph (1) shall use the format listed in Appendix III which constitutes an integral part of this Ministerial Regulation.
(3)	The application referred to in paragraph (1) is submitted by an electronic application through certain channels stipulated by the Director General of Taxes.
(4)	In the event that the certain channels referred to in paragraph (3) are not yet available, the application may be submitted in writing:
	a.	in person; or
	b.	by post or a shipping company or courier services with proof of postage, to the Tax Office where the Taxpayer is registered.
(5)	The Head of the Tax Office on behalf of the Director General of Taxes, based on examination results issues:
	a.	a letter of approval for the application for the imposition of Income Tax only on income received or accrued from Indonesia, if the requirements referred to in Article 8 are fulfilled; or
	b.	a letter of rejection of the application for the imposition of Income Tax only on income received or accrued from Indonesia, if the requirements referred to in Article 8 are not fulfilled,
	within a maximum period of 10 (ten) working days after the application referred to in paragraph (1) is completely received.
(6)	The provisions on the format of documents in the form of:
	a.	the letter of approval of the application referred to in paragraph (5) subparagraph a; and
	b.	the letter of rejection of the application referred to in paragraph (5) subparagraph b,
	are listed in Appendix IV which constitutes an integral part of this Ministerial Regulation.

Article 12
(1)	Foreign Nationals file income through Annual Tax Returns for:
	a.	income received or accrued from Indonesia, if a letter of approval is issued for the application for the imposition of Income Tax only on income received or accrued from Indonesia as referred to in Article 11 paragraph (5) subparagraph a; or
	b.	income received or accrued from Indonesia and overseas, if a letter of rejection is issued for the application for the imposition of Income Tax only on income received or accrued from Indonesia as referred to in Article 11 paragraph (5) subparagraph b.
(2)	Prior to filing income referred to in paragraph (1), the Foreign National calculates income pursuant to statutory provisions.
(3)	The provisions on the calculation of the imposition of Income Tax only on income received or accrued from Indonesia are listed in Appendix V which constitutes an integral part of this Ministerial Regulation.

Article 13
(1)	Foreign Nationals with certain skills who had constituted tax residents before the enactment of this Ministerial Regulation, may be subject to Income Tax only on income received or accrued from Indonesia insofar as the following requirements are fulfilled:
	a.	the period of 4 (four) Tax Years referred to in Article 7 paragraph (2) subparagraph b has not elapsed; and
	b.	applying as referred to in Article 11 paragraph (1).
(2)	In the event that the application referred to in paragraph (1) subparagraph b is approved, the imposition of Income Tax only on income received or accrued from Indonesia is calculated from the enactment of Law Number 11 of 2020 concerning Job Creation until the end of the period referred to in Article 7 paragraph (2) subparagraph b.

Section Three Criteria, Procedures and Certain Periods for Investments, Procedures for the Exclusion from the Imposition of Income Tax on Dividends or Other Income Excluded from Taxable Objects as Well as Changes in the Threshold on Invested Dividends Paragraph 1 Dividends Excluded from Income Tax Objects Article 14
(1)	Dividends that are excluded from Income Tax objects are Dividends sourced:
	a.	domestically; or
	b.	overseas,
	received or accrued by a Taxpayer.
(2)	The Taxpayer referred to in paragraph (1) constitutes a resident Taxpayer.

Article 15
(1)	Domestically-sourced dividends referred to in Article 14 paragraph (1) subparagraph a received or accrued by resident individual Taxpayers are excluded from Income Tax objects provided that they must be invested in the territory of the Unitary State of the Republic of Indonesia within a certain period.
(2)	Domestically-sourced dividends referred to in Article 14 paragraph (1) subparagraph a received or accrued by resident corporate Taxpayers are excluded from Income Tax objects.

Article 16
(1)	In the event that the Dividends referred to in Article 14 paragraph (1) subparagraph a invested in the territory of the Unitary State of the Republic of Indonesia are less than the total Dividends received or accrued by the resident individual Taxpayer, the invested Dividends are excluded from the imposition of Income Tax.
(2)	The difference of received or accrued Dividends less the invested Dividends referred to in paragraph (1) is subject to Income Tax pursuant to statutory provisions.

Article 17
(1)	Foreign-sourced Dividends referred to in Article 14 paragraph (1) subparagraph b received or accrued by a Taxpayer referred to in Article 14 are excluded from Income Tax objects.
(2)	Foreign-sourced Dividends referred to in paragraph (1) are excluded from Income Tax objects provided that they must be invested or used to support other businesses within the territory of the Unitary State of the Republic of Indonesia within a certain period.
(3)	Foreign-sourced Dividends referred to in paragraph (1) are:
	a.	distributed Dividends sourced from a listed offshore company received or accrued by the Taxpayer; or
	b.	distributed Dividends sourced from a non-listed offshore company as per the proportion of shareholding.

Article 18
Distributed Dividends sourced from a listed offshore company referred to in Article 17 paragraph (3) subparagraph a are excluded from Income Tax objects in the amount of Dividends invested in the territory of the Unitary State of the Republic of Indonesia within a certain period.

Article 19
In the event that the Distributed Dividends sourced from a listed offshore company referred to in Article 18 invested in the territory of the Unitary State of the Republic of Indonesia are less than the Dividends received or accrued by the Taxpayer, the invested Dividends are excluded from the imposition of Income Tax.

Article 20
The difference of the Dividends received or accrued by the Taxpayer less the invested Dividends referred to in Article 19 is subject to Income Tax pursuant to statutory provisions.

Article 21
(1)	In addition to fulfilling the requirements referred to in Article 17 paragraph (2), distributed Dividends sourced from a non-listed offshore company referred to in Article 17 paragraph (3) subparagraph b, must be invested in the territory of the State Unitary Republic of Indonesia within a certain period, by a minimum of 30% (thirty per cent) of Net Income After Tax.
(2)	Dividends referred to in paragraph (1) must be invested before the Director General of Taxes issues a notice of tax assessment on such Dividends in connection with the application of the provisions referred to in Article 18 paragraph (2) of the Income Tax Law.
(3)	Dividends referred to in paragraph (1) which are invested after the Director General of Taxes issues a notice of tax assessment on such Dividends in connection with the application of provisions referred to in Article 18 paragraph (2) of the Income Tax Law, such Dividends are not excluded from the imposition of Income Tax.
(4)	Dividends referred to in paragraph (1) are Dividends sourced from Net Income After Tax starting the 2020 Tax Year, received or accrued as of 2 November 2020.

Article 22
(1)	In the event that the Dividends referred to in Article 21 paragraph (1) invested in the territory of the Unitary State of the Republic of Indonesia are less than 30% (thirty per cent) of the total Net Income After Tax, the invested Dividends are excluded from the imposition of Income Tax.
(2)	The difference of 30% (thirty per cent) of Net Income After Tax less the Dividends invested in the territory of the Unitary State of the Republic of Indonesia referred to in paragraph (1) is subject to Income Tax pursuant to Article 17 of the Income Tax Law.
(3)	Residual Income After Tax less by Dividends invested in the territory of the Unitary State of the Republic of Indonesia referred to in paragraph (1) after subtracted by the difference referred to in paragraph (2), is not subject to Income Tax.

Article 23
(1)	In the event that the Dividends referred to in Article 21 paragraph (1) invested in the territory of the Unitary State of the Republic of Indonesia are more than 30% (thirty per cent) of the total Net Income After Tax, the invested Dividends are excluded from the imposition of Income Tax.
(2)	Residual Income After Tax less the Dividends invested in the territory of the Unitary State of the Republic of Indonesia referred to in paragraph (1) is not subject to Income Tax.

Article 24
(1)	Dividends excluded from Income Tax objects referred to in Article 14 paragraph (1) are Dividends distributed based on:
	a.	General Meeting of Shareholders; or
	b.	Interim Dividends pursuant to statutory provisions.
(2)	General meeting of shareholders or interim Dividends referred to in paragraph (1) include similar meetings and similar Dividend distribution mechanisms.

Paragraph 2 Other Income Excluded from Income Tax Objects Article 25
(1)	Other income excluded from Income Tax objects is other income sourced overseas received or accrued by a Taxpayer.
(2)	Other income referred to in paragraph (1) is:
	a.	income after tax from an overseas permanent establishment; or
	b.	foreign-sourced income not through a permanent establishment.
(3)	Taxpayer referred to in paragraph (1) is a resident Taxpayer.

Article 26
(1)	Income after tax from an overseas permanent establishment referred to in Article 25 paragraph (2) subparagraph a received or accrued by the Taxpayer is excluded from Income Tax objects provided that it must be invested or used to support other businesses in the territory of the Unitary State of the Republic of Indonesia within a certain period.
(2)	In addition to fulfilling the requirements referred to in paragraph (1), income after tax from an overseas permanent establishment must be invested or used to support other businesses in the territory of the Unitary State of the Republic of Indonesia within a certain period, by a minimum of 30% (thirty per cent) of Net Income After Tax.

Article 27
(1)	In the event that income after tax from an overseas permanent establishment referred to in Article 26 paragraph (2) invested in the territory of the Unitary State of the Republic of Indonesia is less than 30% (thirty per cent) of the total Net Income After Tax, the invested income after tax from an overseas permanent establishment is excluded from the imposition of Income Tax.
(2)	The difference of 30% (thirty per cent) of Net Income After Tax less the income after tax from an overseas permanent establishment invested in the territory of the Unitary State of the Republic of Indonesia referred to in paragraph (1) is subject to Income Tax pursuant to Article 17 of the Income Tax Law.
(3)	Residual Income After Tax less the income after tax from an overseas permanent establishment invested in the territory of the Unitary State of the Republic of Indonesia referred to in paragraph (1) and the difference referred to in paragraph (2) are not subject to Income Tax.

Article 28
(1)	In the event that the income after tax from an overseas permanent establishment referred to in Article 26 paragraph (2) invested in the territory of the Unitary State of the Republic of Indonesia is more than 30% (thirty per cent) of the total Net Income After Tax, the invested income after tax from the overseas permanent establishment is excluded from the imposition of Income Tax.
(2)	Residual Income After Tax less income after tax from an overseas permanent establishment invested in the territory of the Unitary State of the Republic of Indonesia referred to in paragraph (1) is not subject to Income Tax.

Article 29
(1)	Foreign-sourced income not through a permanent establishment referred to in Article 25 paragraph (2) subparagraph b received or accrued by the Taxpayer is excluded from Income Tax objects provided that it must be invested in the territory of the Unitary State of the Republic of Indonesia within a certain period.
(2)	In addition to fulfilling the requirements referred to in paragraph (1), foreign-sourced income not through a permanent establishment must fulfil the following requirements:
	a.	the income is sourced from an overseas active business; and
	b.	does not constitute income from an offshore company;
(3)	Foreign-sourced income not through a permanent establishment referred to in paragraph (1) is foreign-sourced income from an overseas business.

Article 30
(1)	In the event that foreign-sourced income not through a permanent establishment referred to in Article 29 paragraph (1) invested in the territory of the Unitary State of the Republic of Indonesia is less than the amount of other income received or accrued by the Taxpayer, the invested foreign-sourced income not through a permanent establishment is excluded from the imposition of Income Tax.
(2)	The difference of foreign-sourced income not through a permanent establishment received or accrued by the Taxpayer less by foreign-sourced income not through a permanent establishment invested in the territory of the Unitary State of the Republic of Indonesia referred to in paragraph (1) is subject to Income Tax pursuant to Article 17 of the Income Tax Law.

Paragraph 3 Foreign Tax Credit Article 31
(1)	To tax on income that has been paid or payable overseas on foreign-sourced foreign-sourced Dividends referred to in Article 17 or other income sourced from overseas referred to in Article 25 which is excluded from Income Tax objects, the following provisions shall apply:
	a.	cannot be taken into account in the income tax payable;
	b.	cannot be charged as an expense or income deduction; and/or
	c.	tax overpayments are non-refundable.
(2)	In the event that foreign-sourced Dividends or other income sourced from overseas received or accrued by a Taxpayer are not fully invested in the territory of the Unitary State of the Republic of Indonesia, the tax credit for withholding tax overseas is calculated proportionally.

Article 32
The provisions on the calculation of exclusion from Income Tax objects referred to in Article 16, Article 19, Article 22, Article 27 and Article 30 are listed in Appendix VI which constitutes an integral part of this Ministerial Regulation.

Paragraph 4 Certain Criteria, Procedures and Periods for Investments Article 33
Investments referred to in Article 15, Article 17, Article 26 and/or Article 29 must fulfil certain criteria, procedures and periods.

Article 34
Investments referred to in Article 15, Article 17, Article 26 and/or Article 29 are performed according to the criteria for the forms of investment:
a.	government of the Republic of Indonesia and sharia securities of the Republic of Indonesia;
b.	bonds or sharia bonds of State-Owned Enterprises whose trading is supervised by the Financial Services Authority;
c.	bonds or sharia bonds of financing institutions owned by the government whose trading is supervised by the Financial Services Authority;
d.	financial investment in banks for revenue collection, including Sharia banks;
e.	bonds or sharia bonds of private companies whose trading is supervised by the Financial Services Authority;
f.	infrastructure investments through government cooperation with business entities;
g.	real sector investment based on priorities determined by the government;
h.	capital participation in companies newly incorporated and domiciled in Indonesia as shareholders;
i.	capital participation in companies that have been incorporated and domiciled in Indonesia as shareholders;
j.	cooperation with investment management institutions;
k.	use to support other businesses in the form of loans to micro and small businesses within the territory of the Unitary State of the Republic of Indonesia pursuant to statutory provisions in the field of micro, small and medium enterprises; and/or
l.	other forms of legitimate investments pursuant to statutory provisions.

Article 35
(1)	Investments referred to in Article 34 subparagraph a to subparagraph e and subparagraph l, are placed in investment instruments in financial markets:
	a.	debt securities, including medium-term notes;
	b.	sharia bonds;
	c.	shares;
	d.	participating units of mutual funds;
	e.	asset-backed securities;
	f.	participating units of real estate investment trusts;
	g.	time deposits;
	h.	savings accounts;
	i.	current accounts;
	j.	futures contracts traded on futures exchanges in Indonesia; and/or
	k.	other financial market investment instruments, including insurance products linked to investments, finance companies, pension funds or venture capital, which are approved by the Financial Services Authority.
(2)	Investments referred to in Article 34 subparagraph f to subparagraph k, are placed in investment instruments outside financial markets:
	a.	infrastructure investments through government cooperation with business entities;
	b.	real sector investments based on priorities stipulated by the government;
	c.	investments in property in the form of land and/or buildings erected thereon;
	d.	direct investments in companies in the territory of the Unitary State of the Republic of Indonesia;
	e.	investments in precious metals in the form of gold bullion;
	f.	cooperation with investment management institutions;
	g.	use to support other businesses in the form of loans to micro and small businesses within the territory of the Unitary State of the Republic of Indonesia pursuant to statutory provisions in the field of micro, small and medium enterprises; and/or
	h.	other legitimate forms of investments outside financial markets pursuant to statutory provisions.
(3)	Investments referred to in paragraph (2) subparagraph b and subparagraph d are performed through the mechanisms of capital participation in a company in the form of a limited liability company.
(4)	Sectors constituting the government’s priority in real sector investments referred to in paragraph (2) subparagraph b include sectors specified in the National Medium-Term Development Plan.
(5)	Property referred to in paragraph (2) subparagraph c does not include property subsidised by the government.
(6)	Precious metals referred to in paragraph (2) subparagraph e are 99.99% (ninety-nine point ninety-nine per cent) carat gold bullion.
(7)	Gold bullion referred to in paragraph (6) is gold produced in Indonesia and is accredited and certified by the Indonesian National Standard (SNI) and/or the London Bullion Market Association (LBMA).

Article 36
(1)	Investments referred to in Article 35 are performed no later than:
	a.	the end of the third month, for individual Taxpayers; or
	b.	the end of the fourth month, for corporate Taxpayers,
	after the Tax Year ends, for the Tax Year in which the dividends or other income are received or accrued.
(2)	Investments referred to in Article 35 are performed for a minimum of 3 (three) Tax Years as of the Tax Year the Dividends or other income are received or accrued.
(3)	Investments referred to in Article 35 are not transferable, except in the form of investments referred to in Article 35.

Paragraph 5 Procedures for the Exclusion of Imposition of Income Tax on Dividends or Other Income Article 37
(1)	Exclusion from Income Tax objects of domestically-sourced Dividends referred to in Article 14 paragraph (1) subparagraph a received or accrued by:
	a.	resident individual Taxpayers referred to in Article 15 paragraph (1); or
	b.	resident corporate Taxpayers referred to in Article 15 paragraph (2),
	is carried out by filing domestically-sourced Dividends in the Annual Tax Return as income not included as taxable objects.
(2)	Domestically-sourced Dividends which are excluded from Income Tax objects referred to in paragraph (1) shall not be subject to Withholding Tax by the withholding agent without a Withholding Certificate.
(3)	Exclusion from Income Tax objects of foreign-sourced Dividends referred to in Article 14 paragraph (1) subparagraph b is carried out by filing foreign-sourced Dividends in the Annual Tax Return as income not included as taxable objects.

Article 38
Exclusion from Income Tax objects for other income sourced from overseas referred to in Article 25 is carried out by filing other income sourced from overseas in the Annual Tax Return as income not included as taxable objects.

Article 39
Dividends or other income that does not fulfil the criteria for the forms of investments referred to in Article 34, procedure referred to in Article 35 and investment period referred to in Article 36, is subject to Income Tax payable the time the Dividends or other income is received or accrued.

Article 40
(1)	Income Tax payable on domestically-sourced Dividends referred to in Article 16 paragraph (2) and/or Article 39, must be self-remitted by resident individual Taxpayers at a rate pursuant to statutory provisions.
(2)	Income Tax referred to in paragraph (1) shall be remitted no later than the 15th (fifteenth) of the following month after the Taxable Periods in which the Dividends are received or accrued.
(3)	An individual Taxpayer that pays Income Tax payable referred to in paragraph (1) and has received validation with an NTPN is deemed to have filed a Periodic Income Tax Return according to the validation date.

Article 41
(1)	Taxpayers referred to in Article 15 paragraph (1), Article 17 paragraph (1), and/or Article 25 paragraph (1) must submit investment realisation reports.
(2)	Reports referred to in paragraph (1) are submitted by electronic submission of the reports through certain channels stipulated by the Director General of Taxes.
(3)	In the event that certain channels referred to in paragraph (2) are not yet available, the reports may be submitted in writing:
	a.	in person; or
	b.	by post or a shipping company or courier services with proof of postage,
	to the Tax Office where the Taxpayer is registered.
(4)	Taxpayers must submit reports referred to in paragraph (1):
	a.	periodically no later than the end of the third month for individual Taxpayers or the end of the fourth month for Corporate taxpayers after the Tax Year ends; and
	b.	submitted until the third year since the Tax Year the Dividends or other income are received or accrued.
(5)	The provisions on the format of documents in the form of investment realisation reports are listed in Appendix VII which constitutes an integral part of this Ministerial Regulation.
(6)	The provisions on report submission are listed in Appendix VIII which constitutes an integral part of this Ministerial Regulation.

Paragraph 6 Changes in the Threshold of Invested Dividends Article 42
In the event that there is a need for changes in the threshold of invested Dividends, the threshold of invested Dividends may be changed.

Article 43
The provisions on changes to the threshold of invested Dividends referred to in Article 21 paragraph (1) are regulated by a Minister of Finance Regulation.

Section Four Deposit Funds for Hajj Fees and/or Special Hajj Fees and Income from the Development of Hajj Finances in Certain Fields or Financial Instruments Excluded from Income Tax Article 44
Revenues of the BPKH include:
a.	deposit funds for BPIH and/or Special BPIH;
b.	the value of hajj financial benefits in the form of income from the development of hajj finances;
c.	efficiency fund for hajj;
d.	people’s endowment fund; and/or
e.	other legal and non-binding sources.

Article 45
(1)	Deposit funds for BPIH and/or special BPIH referred to in Article 44 subparagraph a and income from the development of hajj finances in certain fields or financial instruments referred to in Article 44 subparagraph b, received by the BPKH are excluded from Income Tax objects.
(2)	Income from the development of hajj finances in certain fields or financial instruments referred to in paragraph (1) in the form of:
	a.	yield from current accounts, time deposits, certificates of deposit and savings accounts, at banks in Indonesia that conduct business based on sharia principles as well as sharia securities issued by Bank Indonesia;
	b.	yield from sharia bonds, Government Securities and Sharia Treasury Notes, which are traded and/or whose trade is reported on a stock exchange in Indonesia;
	c.	domestically-sourced and foreign-sourced Dividends or other income in the form of income after tax or income excluded from taxes or subject to 0% (zero per cent) tax from a permanent establishment or not through an overseas permanent establishment;
	d.	surplus received or accrued from holders of participating units of collective investment contracts which may take the form of yield from sharia mutual funds, collective investment contracts of asset-backed securities, collective investment contracts of real estate investment trusts, collective investment contracts of infrastructure investment funds and/or collective investment contracts based on similar sharia principles; and/or
	e.	sales of investments in the form of gold bullion or gold accounts managed by sharia financial institutions,
	pursuant to statutory provisions.
(3)	Income referred to in paragraph (2) subparagraph a, subparagraph b, subparagraph c and subparagraph d, as well as the purchase of gold bullion or gold accounts referred to in paragraph (2) subparagraph e is excluded from Withholding Tax.
(4)	The exclusion from Withholding Tax referred to in paragraph (3) is granted based on an exemption certificate.
(5)	To obtain the exemption certificate referred to in paragraph (4), the BPKH must apply to the Head of the Tax Office where the BPKH is registered.
(6)	The provisions on the format of the application referred to in paragraph (5) are listed in Appendix IX which constitutes an integral part of this Ministerial Regulation.
(7)	Application referred to in paragraph (5) is submitted:
	a.	in person; or
	b.	by post or a shipping company or courier services with proof of postage,
	to the Tax Office where the BPKH is registered.
(8)	The Head of the Tax Office on behalf of the Director General of Taxes issues the exemption certificate within a maximum period of 5 (five) working days after the application referred to in paragraph (5) is completely received
(9)	The provisions on the format of documents in the form of the certificate referred to in paragraph (8) are listed in Appendix X which constitutes an integral part of this Ministerial Regulation.
(10)	The certificate referred to in paragraph (4) constitutes the basis for parties conducting transactions with the BPKH not to withhold Income Tax as referred to in paragraph (3).
(11)	Income that is excluded as Income Tax objects referred to in paragraph (2) does not include income from the development of people’s endowment fund referred to in Article 44 subparagraph d.
(12)	In the event that income from the development of people’s endowment fund referred to in paragraph (11) subject to final Income Tax is not subject to Withholding Tax referred to in paragraph (3), the the BPKH shall self-remit Income Tax payable.
(13)	Self-remittance of Income Tax payable referred to in paragraph (12) is carried out no later than the 15th (fifteenth) of the following month after the Taxable Period the income is received or accrued.
(14)	In the event that Income Tax payable referred to in paragraph (13) has been remitted and validated with an NTPN, the BPKH shall be deemed to have filed the Periodic Income Tax Return according to the validation date.
(15)	Income received or accrued by the BPKH other than:
	a.	deposit funds BPIH and/or Special BPIH referred to in paragraph (1);
	b.	income from the development of hajj finances referred to in paragraph (2); and
	c.	income from the development of people’s endowment fund on which the Income Tax is self-remitted by the BPKH referred to in paragraph (12),
	is subject to Income Tax pursuant to statutory provisions in the field of taxation.

Article 46
(1)	The BPKH must maintain separate bookkeeping if:
	a.	owning a business whose income is subject to final and non-final Income Tax; or
	b.	receiving or accruing income constituting a taxable and non-taxable object.
(2)	Expenses related to income which:
	a.	are excluded from Income Tax objects referred to in Article 45 paragraph (1); and/or
	b.	have been subject to final Income Tax, cannot be deducted from gross income.
(3)	For joint costs related to income excluded from Income Tax objects referred to in Article 45 paragraph (1), income from the development of the people’s endowment funds on which Income Tax is self-remitted by the BPKH referred to in Article 45 paragraph (12) and income referred to in Article 45 paragraph (15), which cannot be separated in the context of Taxable Income calculation, the expensing is allocated proportionally;

Article 47
(1)	The provisions referred to in Article 45 paragraph (1) are effective as of the date of promulgation of Law Number 11 of 2020 concerning Job Creation.
(2)	For income referred to in Article 45 paragraph (1) which has been subject to final Withholding Tax from the date of the promulgation of Law Number 11 of 2020 concerning Job Creation, the BPKH may apply for tax refunds that should not otherwise be payable.
(3)	Procedures for the application for tax refunds that should not otherwise be payable referred to in paragraph (2) are carried out pursuant to the Minister of Finance Regulation concerning tax refunds that should not otherwise be payable.

Section Five Surplus Received or Accrued by Social and/or Religious Bodies or Institutions Excluded from Income Tax Objects Article 48
(1)	The surplus received or accrued by social and/or religious bodies or institutions listed in corresponding agencies, are excluded from Income Tax objects provided that the surplus is used for the construction and/or procurement of social and/or religious means and infrastructure of a minimum of 25% (twenty-five per cent) of the surplus.
(2)	If there is residue from the use of surplus for the construction and/or procurement of social and/or religious means and infrastructure referred to in paragraph (1), the surplus is placed as endowment funds.
(3)	The construction and/or procurement of means and infrastructure as well as the allocation in the form of endowment funds referred to in paragraph (1) and paragraph (2) are carried out within no more than a period of 4 (four) years since the surplus is received or accrued.
(4)	The provisions on the use of surplus referred to in paragraph (3) are listed in Appendix XI which constitutes an integral part of this Ministerial Regulation.
(5)	Social bodies or organisations referred to in paragraph (1) are non-profit social welfare bodies or organisations that constitute legal entities as stipulated under statutory provisions in the field of social welfare and their main activities include organizing:
	a.	free health care;
	b.	care for the elderly or nursing homes;
	c.	care for fatherless and/or motherless orphans, abandoned children or people and children or people with disabilities;
	d.	compensation and/or aid for victims of natural disasters, accidents, poverty, remoteness, social disabilities and behavioral deviations, acts of violence and the like;
	e.	scholarships; and/or
	f.	environmental preservation.
(6)	Religious bodies or institutions referred to in paragraph (1) are non-profit organisations whose main activity is managing places of worship and/or organizing religious activities.
(7)	Corresponding agencies referred to in paragraph (1) are:
	a.	government agencies at the central, provincial or regency/municipal levels in charge of social affairs for socialbodies or institutions; and
	b.	government agencies at the central, provincial or regency/municipal in charge of religious affairs for religious bodies or institutions.
(8)	Surplus referred to in paragraph (1) is the surplus of the calculation of all income received or accrued other than income subject to final Tax Income and/or non Income Tax objects less the costs to obtain, collect and maintain such income.
(9)	The costs to obtain, collect and maintain income referred to in paragraph (8) include:
	a.	aid, donations or gifts;
	b.	operational costs for organizing social and/or religious activities; and/or
	c.	procurement costs of goods and/or services used to support social and/or religious activities.
(10)	Aid, donations or gifts referred to in paragraph (9) subparagraph a may be deducted from gross income pursuant to statutory provisions in the field of taxation, insofar as there is no special relationship as referred to in the Income Tax Law.
(11)	Not included as special relationships in the form of ownership and control relationships referred to in paragraph (10) if the donor and donee of aid, donations or gifts are social and/or religious bodies or organisations as referred to in paragraph (5) and paragraph (6).

Article 49
(1)	Social and/or religious means and infrastructure referred to in Article 48 paragraph (1) include:
	a.	the procurement of social and/or religious facilities;
	b.	the construction and procurement of social and/or religious infrastructure, including buildings, land, offices, houses of worship; and/or
	c.	the procurement of means and infrastructure for public facilities,
	located within the territory of the Unitary State of the Republic of Indonesia.
(2)	The surplus may be allocated in the form of endowment funds as referred to in Article 48 paragraph (2) provided that:
	a.	there are provisions pertaining to endowment funds in social and/or religious bodies or institutions in the form of Presidential Regulations and/or Ministerial Regulations in charge of social or religious affairs; and
	b.	approved by:
		1.	the head of social and/or religious bodies or organisations; and
		2.	government agency officials at the central, provincial or regency/municipal levels in charge of social or religious affairs.
(3)	The surplus in the form of development and/or procurement of means and infrastructure referred to in paragraph (1) subparagraph a and subparagraph b may be given to other social and/or religious bodies or institutions listed in corresponding agencies insofar as the said means and infrastructure are within the territory of the Unitary State of the Republic of Indonesia.
(4)	The surplus referred to in paragraph (1) subparagraph c and paragraph (3) may not be deducted from gross income for the social and/or religious bodies or institutions providing such surplus.
(5)	Social and/or religious means and infrastructure referred to in paragraph (1) subparagraph a and subparagraph b with a useful life of more than 1 (one) year are charged through depreciation or amortisation as pursuant to statutory provisions in the field of Income Tax.

Article 50
(1)	Social and/or religious bodies or institutions must file the amount of surplus used for the construction and/or procurement of means and infrastructure and/or allocated in the form of endowment funds referred to in Article 48 paragraph (1) and paragraph (2).
(2)	The report on the amount of surplus referred to in paragraph (1) is submitted annually to the Head of the Tax Office where the social and/or religious bodies or institutions are registered as an attachment to the Annual Tax Return.
(3)	The provisions on the filing of the amount of surplus referred to in paragraph (1) are listed in Appendix XII which constitutes an integral part of this Ministerial Regulation.
(4)	In addition to the report referred to in paragraph (1), social and/or religious bodies or institutions should m notes on details of the use of surplus supplemented with supporting evidence.

Article 51
(1)	The surplus that is not used for the construction and/or procurement of means and infrastructure or endowment funds within a period of 4 (four) years as referred to in Article 48 paragraph (3) is recognised as an Income Tax object at the end of the Tax Year after the period of 4 (four) years ends.
(2)	The amount of surplus referred to in paragraph (1) must be filed as an additional Income Tax object in the Annual Income Tax Return for the Tax Year in which the surplus is recognised as a fiscal correction.
(3)	The provisions on the calculation of the amount of surplus not used for the construction and/or procurement of means and infrastructure or endowment funds within the period of 4 (four) years as referred to in paragraph (1) are listed in Appendix XIII which constitutes an integral part of this Ministerial Regulation.

Article 52
(1)	Endowment funds referred to in Article 48 paragraph (2) may be developed based on sound business practices and managed risks, taking into account the principles of good governance and pursuant to statutory provisions.
(2)	Yield from the development of endowment funds referred to in paragraph (1):
	a.	is subject to tax pursuant to statutory provisions in the field of taxation; and
	b.	may be used for operational activities, specifically for the procurement of social and/or religious means and infrastructure.
(3)	In the event that the use of endowment funds sourced from the surplus referred to in Article 49 paragraph (2) does not comply with the provisions of paragraph (1), the endowment funds shall constitute an Income Tax object in the Tax Year they are found and treated as a fiscal correction.

Article 53
In the event that the social and/or religious bodies or organisations are mainly engaged in education and/or research and development, the surplus for the social and/or religious bodies or organisations shall be treated in accordance with the Minister of Finance Regulation concerning the Income Tax treatment on scholarships that fulfill certain requirements and the surplus received or accrued by non-profitbodies or institutions engaged in education and/or research and development.

CHAPTER III VALUE ADDED TAX AND SALES TAX ON LUXURY GOODS Section One Criteria of Not Having Performed Supplies of Taxable Goods and/or Taxable Services and/or Exports of Taxable Goods and/or Taxable Services, Determination of Certain Business Sectors as well as Procedures for the Refund of Input VAT Article 54
(1)	Taxable Persons that Have Not Performed Any Supply may credit Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods as well as utilisation of intangible Taxable Goods and/or utilisation of Taxable Services from outside the Customs Territory within the Customs Territory.
(2)	Input VAT referred to in paragraph (1) shall be credited pursuant to the provisions on Input VAT crediting regulated under statutory provisions in the field of taxation.
(3)	Taxable Persons that Have Not Performed Any Supply may apply for a refund of Input VAT overpayment at the end of the accounting year.

Article 55
(1)	Creditable Input VAT referred to in Article 54 paragraph (1) becomes non-creditable, if within a certain period:
	a.	the Taxable Person Has Not Performed Any Supply; or
	b.	the Taxable Person Has Not Performed Any Supply dissolved (terminated) the business or the Taxable Person is deregistered based on an application or ex officio.
(2)	The criteria for not having performed supplies referred to in paragraph (1) is a state in which a Taxable Person whose main business is in the sector of:
	a.	trading, if within a certain period does not carry out the following activities:
		1.	supplies of Taxable Goods; and/or
		2.	exports of Taxable Goods;
	b.	services, if within a certain period does not carry out the following activities:
		1.	supplies of Taxable Services; and/or
		2.	exports of Taxable Services; or
	c.	producing Taxable Goods, if within a certain period does not carry out the following activities:
		1.	supplies of self-produced Taxable Goods; and/or
		2.	exports of self-produced Taxable Goods.
(3)	Included in the criteria of not having performed supplies referred to in paragraph (2) is if within the certain period as referred to in paragraph (1) Taxable Person solely carries out the following activities:
	a.	personal use and/or free-of-charge Taxable Goods and/or Taxable Services;
	b.	supplies from the head office to branches or vice versa and/or supplies between branches;
	c.	supplies of Taxable Goods in the form of assets which, according to their original purpose, are not for sale; and/or
	d.	supplies of Taxable Goods and/or Taxable Services that are not directly related to the Taxable Person ’ main business.

Article 56
(1)	The certain period referred to in Article 55 paragraph (1) is a period of up to 3 (three) years since the Taxable Period of the first Input VAT crediting.
(2)	The certain period referred to in paragraph (1) for certain business sectors may be determined to more than 3 (three) years.
(3)	The determination of certain period for certain business sectors referred to in paragraph (2) is limited to:
	a.	business sectors producing Taxable Goods referred to in Article 55 paragraph (2) subparagraph c, the period is set to 5 (five) years since the Taxable Period of the first Input VAT crediting; or
	b.	business sectors included in the statutory provisions on the acceleration of national strategic projects assigned by the government, the period is set for 6 (six) years since the Taxable Period of the first Input VAT crediting.

Article 57
(1)	If Taxable Persons that Have Not Performed Any Supply change their business in a certain period as referred to in Article 56 paragraph (1) or paragraph (3) subparagraph a and the credited Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods as well as utilisation of intangible Taxable Goods and/or utilisation Taxable Services from outside the Customs Territory within the Customs Territory is directly related to the new business, the credited input VAT for which an application for refund has not been submitted is creditable.
(2)	If Taxable Persons that Have Not Performed Any Supply change their business in a certain period as referred to in Article 56 paragraph (1) or paragraph (3) subparagraph a and the credited Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods as well as utilisation of intangible Taxable Goods and/or utilisation Taxable Services from outside the Customs Territory within the Customs Territory is not directly related to the new business, the credited input VAT for which an application for refund has not been submitted becomes non-creditable.
(3)	Taxable Persons that Have Not Performed Any Supply that change their business in a certain period as referred to in Article 56 paragraph (1) or paragraph (3) subparagraph a must refund the Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods as well as utilisation of intangible Taxable Goods and/or utilisation of Taxable Services from outside the Customs Territory within the Customs Territory if:
	a.	the Input VAT is not directly related to the new business; and
	b.	the Taxable Persons have received tax refunds of the Input VAT and/or have credited the said Input VAT against the Output VAT payable in a Taxable Period.
(4)	Taxable Persons must amend the Periodic VAT Return in the event that Input VAT becomes non-creditable as referred to in paragraph (2).

Article 58
(1)	Non-creditable Input VAT referred to in Article 55 paragraph (1), after the certain period referred to in Article 56 paragraph (1) or paragraph (3) ends:
a.	must be refunded to the state treasury by the Taxable Persons ; and/or
b.	cannot be carried forward to the next Taxable Period and application for refunds cannot be submitted.
(2)	The obligation to refund non-creditable Input VAT referred to in paragraph (1) subparagraph a is carried out in the event that the Taxable Persons have received the tax refunds for the said Input VAT and/or have credited the said Input VAT against Output VAT payable in a Taxable Period.
(3)	Input VAT cannot be carried forward to the next Taxable Period and application for refunds cannot be submitted referred to in paragraph (1) subparagraph b if the said tax refunds have been carried forward and a refund has not been requested.
(4)	Output VAT referred to in paragraph (2) includes Output VAT on the activities referred to in Article 55 paragraph (3).

Article 59
(1)	Refund of Input VAT referred to in Article 58 paragraph (2) amounts to Input VAT for which tax refunds have been granted and/or have been credited against Output VAT payable in a Taxable Period.
(2)	Refund of Input VAT referred to in paragraph (1) becomes payable upon:
	a.	certain period referred to in Article 56 paragraph (1) or paragraph (3) ends;
	b.	the date of dissolution (termination) of the business or the deregistration of Taxable Persons referred to in Article 55 paragraph (1) subparagraph b; or
	c.	the Taxable Period in which the change in the business is carried out as referred to in Article 57 paragraph (3).
(3)	Refund of Input VAT referred to in paragraph (1), is carried out no later than:
	a.	the end of the month following the date the certain period referred to in Article 56 paragraph (1) ends;
	b.	the end of the following month after the date the certain period for certain business sectors referred to in Article 56 paragraph (3) ends; or
	c.	the end of the following month after the date of dissolution (termination) of the business or the deregistration of Taxable Persons referred to in Article 55 paragraph (1) subparagraph b.
(4)	In the event that Taxable Persons change their business as referred to in Article 57 paragraph (3), Input VAT is refunded no later than the end of the following month after the Taxable Period of the change in business.
(5)	Refund of Input VAT referred to in paragraph (1) shall be performed using a Tax Payment Slip or other administrative means equivalent to a Tax Payment Slip pursuant to statutory provisions by including the information “Refund of Input VAT” in the description column.
(6)	Refund of Input VAT referred to in paragraph (5) uses account tax code 411219 for other VAT and remittance type code 100 for payments of other VAT payable.
(7)	Refund of Input VAT referred to in paragraph (5), cannot be credited as Input VAT.
(8)	Refund of Input VAT referred to in paragraph (5), is filed in the Periodic VAT Return for the Taxable Period payment is performed by the Taxable Persons .
(9)	The provisions on the refund of Input VAT referred to in paragraph (1) and the filing in the Periodic VAT Return referred to in paragraph (8) are listed in Appendix XIV which constitutes an integral part of this Ministerial Regulation.

Article 60
(1)	Director General of Taxes may audit Taxable Persons that Have Not Performed Any Supply referred to in Article 55 paragraph (1) pursuant to statutory provisions in the field of taxation.
(2)	For Taxable Persons that do not or under refund Input VAT in the period referred to in Article 59 paragraph (3) or paragraph (4), Notice of Tax Underpayment Assessment is issued pursuant to statutory provisions in the field of taxation.
(3)	Notice of Tax Underpayment Assessment referred to in paragraph (2) is issued for the amount of Input VAT refund referred to in Article 59 paragraph (1) plus the administrative penalties referred to in Article 13 paragraph (2a) of the General Provisions and Tax Procedures Law.
(4)	Taxable Persons that refund Input VAT after the due date of tax payments referred to in Article 59 paragraph (3) or paragraph (4), are subject to administrative penalties in the form of interest referred to in Article 9 paragraph (2a) of the General Provisions and Tax Procedures Law.
(5)	Refund of Input VAT listed in the Notice of Tax Underpayment Assessment referred to in paragraph (3), is not included in creditable Input VAT referred to in Article 9 paragraph (9c) of the VAT Law.
(6)	The Director General of Taxes deregisters Taxable Persons ex officio for Taxable Persons that Have Not Performed Any Supply after passing the certain period referred to in Article 56 paragraph (1) or paragraph (3).

Article 61
In the event that Taxable Persons Have Not Performed Any Supply as referred to in Article 55 paragraph (1) subparagraph a due to force majeure with a national disaster status declared by the competent authority/agency, the Taxable Persons are not obliged to refund Input VAT referred to in Article 59 paragraph (1).

Section Two Procedures for Input VAT Crediting Article 62
(1)	Input VAT in a Taxable Period is credited against Output VAT in the same Taxable Period.
(2)	For Taxable Persons that have performed supplies of Taxable Goods, supplies of Taxable Services, exports of Taxable Goods, and/or exports of Taxable Services but in a Taxable Period, there are no such supplies of and/or exports, the input VAT in the said Taxable Period may be credited by the Taxable Persons pursuant to statutory provisions in the field of taxation.
(3)	VAT listed in the Tax Invoice that fulfils the provisions under Article 13 paragraph (5) and paragraph (9) of the VAT Law is Input VAT that may be credited by a Taxable Person in a Taxable Period since the Entrepreneur is registered as a Taxable Person pursuant to statutory provisions in the field of taxation.
(4)	VAT listed in certain documents equivalent to Tax Invoices that fulfil the provisions under Article 13 paragraph (6) and paragraph (9) of the VAT Law is Input VAT that may be credited by a Taxable Person in a Taxable Period since the Entrepreneur is registered as a Taxable Person pursuant to statutory provisions in the field of taxation.

Article 63
(1)	Creditable Input VAT referred to in Article 62 paragraph (1), but not yet credited against Output VAT in the same Taxable Period, may be credited in the next Taxable Period no later than 3 (three) Taxable Periods after the end of the Taxable Period in which the Tax Invoice is prepared.
(2)	Creditable Input VAT referred to in paragraph (1) must be Input VAT that has not been expensed or has not been added (capitalised) in the acquisition price of Taxable Goods or Taxable Services and complies with statutory provisions in the field of taxation.
(3)	Input VAT crediting in the next Taxable Period referred to in paragraph (1) shall be carried out by Taxable Persons through the filing or amendment of Periodic VAT Returns.
(4)	The provisions on Input VAT crediting referred to in paragraph (1) are listed in Appendix XV which constitutes an integral part of this Ministerial Regulation.

Article 64
(1)	Tax Invoice prepared by stating the identity of the buyer of Taxable Goods or Taxable Service recipient in the form of the name, address and national identification number for individual tax residents pursuant to statutory provisions is a Tax Invoice that fulfils the provisions under Article 13 paragraph (5) subparagraph b number 1 of the VAT Law.
(2)	VAT listed in the Tax Invoice referred to in paragraph (1) is Input VAT that may be credited by a Taxable Person purchasing Taxable Goods or receiving Taxable Services pursuant to statutory provisions in the field of taxation.
(3)	The provisions on Input VAT crediting referred to in paragraph (2) are listed in Appendix XVI which constitutes an integral part of this Ministerial Regulation.

Article 65
(1)	Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods as well as utilisation of intangible Taxable Goods and/or utilisation of Taxable Services from outside the Customs Territory within the Customs Territory before an Entrepreneur is registered as a Taxable Person , may be credited by the Taxable Person .
(2)	Provisions on Input VAT crediting referred to in paragraph (1) apply to the Taxable Period before the Entrepreneur is registered as a Taxable Person, namely the Taxable Period prior to the registration date of the Entrepreneur as a Taxable Person as stated in the Taxable Person registration letter.
(3)	Input VAT referred to in paragraph (1) is credited against Output VAT that should be collected by Taxable Persons on supplies of Taxable Goods and/or Taxable Services since the Entrepreneur should be registered as a Taxable Person pursuant to statutory provisions in the field of taxation until the Entrepreneur is registered as a Taxable Person .
(4)	Input VAT referred to in paragraph (1) is calculated using the Input VAT crediting guidelines of 80% (eighty per cent) of the Output VAT that should be collected as referred to in paragraph (3).
(5)	Guidelines for Input VAT crediting referred to in paragraph (4) are applied to the Taxable Period before the Entrepreneur is registered as a Taxable Person , which is carried out through:
	a.	the filing of Periodic VAT Return; and/or
	b.	the determination of VAT liabilities through audits.
(6)	VAT listed in the Tax Invoice and certain documents equivalent to a Tax Invoice for a Taxable Period before the Entrepreneur is registered as a Taxable Person , is non-creditable Input VAT.
(7)	To use the Input VAT crediting guidelines referred to in paragraph (4), Taxable Persons may not use:
	a.	other values as the Tax Base as referred to in Article 8A of the VAT Law to calculate Output VAT that should be collected on supplies of Taxable Goods and/or Taxable Services; and
	b.	guidelines for calculating Input VAT crediting for Taxable Persons whose business turnover in 1 (one) year does not exceed a certain amount as referred to in Article 9 paragraph (7) of the VAT Law or those who conduct certain businesses as referred to in Article 9 paragraph (7a) of the VAT Law to calculate the amount of creditable Input VAT.
(8)	Periodic VAT Return referred to in paragraph (5) subparagraph a, is:
	a.	Periodic VAT Return, for Taxable Persons that do not use the guidelines for calculating input VAT crediting referred to in Article 9 paragraph (7) and paragraph (7a) of the VAT Law; or
	b.	Periodic VAT Returns for Taxable Persons that use guidelines for calculating Input VAT crediting, for Taxable Persons that use guidelines for calculating Input VAT crediting referred to in Article 9 paragraph (7) and paragraph (7a) of the VAT Law.
(9)	Periodic VAT Return referred to in paragraph (8) is filed by Taxable Persons since the Entrepreneur should be registered as a Taxable Person in:
	a.	the last Taxable Period in the accounting year before the accounting year in which the Entrepreneur is registered as a Taxable Person , which includes Output VAT on supplies of Taxable Goods and/or Taxable Services for the accounting year period concerned; and/or
	b.	the last Taxable Period before the Entrepreneur registered as a Taxable Person in the accounting year in which the Entrepreneur is registered as a Taxable Person , which includes Output VAT on supplies of Taxable Goods and/or Taxable Services before Entrepreneur registered as Taxable Persons for the accounting year period concerned.
(10)	The provisions on Input VAT crediting referred to in paragraph (3) and the filing of Periodic VAT Returns referred to in paragraph (9) are listed in Appendix XVII which constitutes an integral part of this Ministerial Regulation.

Article 66
(1)	An Entrepreneur that does not prepare Tax Invoices for supplies of Taxable Goods and/or Taxable Services before the Entrepreneur is registered as a Taxable Person does not fulfil the provisions stipulated under Article 14 paragraph (1) subparagraph d of the General Provisions and Tax Procedures Law and is not subject to administrative penalties stipulated under Article 14 paragraph (4) of the General Provisions and Tax Procedures Law.
(2)	Taxable Persons referred to in Article 65 paragraph (3), are subject to administrative penalties in the form of:
	a.	fines as referred to in Article 7 paragraph (1) of the General Provisions and Tax Procedures Law;
	b.	interest as referred to in Article 9 paragraph (2a) of the General Provisions and Tax Procedures Law or Article 13 paragraph (2) of the General Provisions and Tax Procedures Law; and/or
	c.	surcharges as referred to in Article 15 of the General Provisions and Tax Procedures Law.
(3)	The calculation of administrative penalties referred to in paragraph (2) subparagraph b is as follows:
	a.	interest as referred to in Article 9 paragraph (2a) of the General Provisions and Tax Procedures Law is calculated from the payment due date for the Taxable Period referred to in Article 65 paragraph (9) until the payment date and is imposed for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month; or
	b.	interest referred to in Article 13 paragraph (2) of the General Provisions and Tax Procedures Law is calculated from the end of the Taxable Period referred to in Article 65 paragraph (9) until the issuance of a Notice of Tax Underpayment Assessment and is imposed for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month.
(4)	Input VAT referred to in Article 65 paragraph (6) may not be expensed or added (capitalised) in the acquisition price of the Taxable Goods or Taxable Services by Taxable Persons crediting the Input VAT using the guidelines for Input VAT crediting guidelines referred to in Article 65 paragraph (4).
(5)	In the event that Input VAT referred to in paragraph (4) has been expensed or has been added (capitalised) to the acquisition price of Taxable Goods or Taxable Services:
	a.	the Taxable Persons are required to amend the Annual Tax Return in the Tax Year in which the Input VAT has been expensed or has been added (capitalised) to the acquisition price of Taxable Goods or Taxable Services; or
	b.	the Director General of Taxes based on the application of Taxable Persons or ex officio amends the assessments or decisions pursuant to the provisions under Article 16 of the General Provisions and Tax Procedures Law.

Article 67
(1)	Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods and utilisation of intangible Taxable Goods and/or utilisation of Taxable Services from outside the Customs Territory within the Customs Territory, which are not filed in the Periodic VAT Return notified and/or discovered during an audit, may be credited by Taxable Persons pursuant to statutory provisions in the field of taxation.
(2)	Input VAT that is not filed in the Periodic VAT Return notified and/or discovered at the time of audit referred to in paragraph (1) is the VAT listed in:
	a.	the Tax Invoices; and/or
	b.	certain documents equivalent to Tax Invoices.
(3)	Input VAT crediting referred to in paragraph (1) is carried out upon the audit to be taken into account in tax assessments to be issued under the documents referred to in paragraph (2) which:
	a.	are notified by Taxable Persons by showing and/or lending the said documents pursuant to the provisions of the Minister of Finance Regulation concerning procedures for audits; and/or
	b.	are discovered by the Director General of Taxes.
(4)	Input VAT crediting referred to in paragraph (1) may be carried out insofar as the notice of tax audit findings has not been submitted to Taxable Persons .
(5)	The provisions on Input VAT crediting referred to in paragraph (1) are listed in Appendix XVIII which constitutes an integral part of this Ministerial Regulation.

Article 68
(1)	Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods and utilisation of intangible Taxable Goods and/or utilisation of Taxable Services from outside the Customs Territory within the Customs Territory, which is collected with the issuance of tax assessments, may be credited by Taxable Persons in the amount of the principal amount stated in the tax assessment, provided that:
	a.	the said tax assessment constitutes a notice of tax assessment issued only to collect Input VAT on the acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods and utilisation of intangible Taxable Goods and/or utilisation of Taxable Services from outside the Customs Territory within the Customs Territory;
	b.	the Taxable Persons approve all audit findings on the tax assessment;
	c.	the amount of outstanding VAT includes the principal tax and penalties as stated in the paid tax assessment;
	d.	no legal action has been taken on the tax assessment; and
	e.	pursuant to statutory provisions in the field of taxation.
(2)	The amount of outstanding VAT referred to in paragraph (1) subparagraph c shall be settled by Taxable Persons using a Tax Payment Slip or other administrative means equivalent to a Tax Payment Slip.
(3)	Tax Payment Slip or other administrative means equivalent to a Tax Payment Slip referred to in paragraph (2) are in the form of:
	a.	state revenue receipt as stipulated under the Minister of Finance Regulation concerning the electronic state revenue system;
	b.	overbooking receipt that has been signed by the competent authority as stipulated under the Minister of Finance Regulation concerning procedures for the payment and remittance of taxes; and/or
	c.	SP2D or state revenue receipt as proof of compensation for Tax Liability as stipulated under the Minister of Finance Regulation concerning calculation procedures and tax refunds.
(4)	No legal action has been taken on the tax assessment referred to in paragraph (1) subparagraph d includes no application for the following is submitted:
	a.	objections as referred to in Article 25 of the General Provisions and Tax Procedures Law;
	b.	appeals as referred to in Article 27 of the General Provisions and Tax Procedures Law;
	c.	relief or nullification of administrative penalties as referred to in Article 36 paragraph (1) subparagraph a of the General Provisions and Tax Procedures Law;
	d.	relief or cancellation of the notice of tax assessment as referred to in Article 36 paragraph (1) subparagraph b of the General Provisions and Tax Procedures Law;
	e.	cancellation of tax audit findings or tax assessments as referred to in Article 36 paragraph (1) subparagraph d of the General Provisions and Tax Procedures Law; and/or
	f.	civil reviews as referred to in statutory provisions on tax court.
(5)	Included in no legal action has been taken referred to in paragraph (4), is no lawsuit as referred to in Article 23 of the General Provisions and Tax Procedures Law is filed.
(6)	Tax assessments which are attached with all Tax Payment Slips or other administrative means equivalent to Tax Payment Slips for the settlement of the amount of outstanding VAT referred to in paragraph (3) constitute certain documents equivalent to Tax Invoices.
(7)	Input VAT crediting referred to in paragraph (1), is carried out by filing certain documents equivalent to Tax Invoice referred to in paragraph (6) in the Periodic VAT Return in the Taxable Period the tax assessment is settled or in the next Taxable Period no later than 3 (three) Taxable Periods after the end of the Taxable Period the tax assessment is settled.
(8)	The provisions on Input VAT crediting referred to in paragraph (1) and filing in Periodic VAT Returns referred to in paragraph (7) are listed in Appendix XIX which constitutes an integral part of this Ministerial Regulation.

Section Three Procedures for the Preparation of Tax Invoices and Procedures for the Amendment or Replacement of Tax Invoices Article 69
(1)	Taxable Persons must prepare a Tax Invoice for each:
	a.	supply of Taxable Goods as referred to in Article 4 paragraph (1) subparagraph a and/or Article 16D of the VAT Law;
	b.	supply of Taxable Services as referred to in Article 4 paragraph (1) subparagraph c of the VAT Law;
	c.	export of tangible Taxable Goods as referred to in Article 4 paragraph (1) subparagraph f of the VAT Law;
	d.	export of intangible Taxable Goods as referred to in Article 4 paragraph (1) subparagraph g of the VAT Law; and/or
	e.	export of Taxable Services as referred to in Article 4 paragraph (1) subparagraph h of the VAT Law.
(2)	Tax Invoice referred to in paragraph (1) must be prepared upon:
	a.	a supply of Taxable Goods and/or Taxable Services;
	b.	receipt of payment if payment is received before the supply of Taxable Goods and/or before the supply of Taxable Services;
	c.	receipt of term payment in the case of a supply of a part of work phases;
	d.	exports of tangible Taxable Goods, exports of intangible Taxable Goods, and/or exports of Taxable Services; or
	e.	certain times regulated by statutory provisions in the field of VAT.

Article 70
(1)	Excluded from the provisions referred to in Article 69 paragraph (1), Taxable Persons may prepared 1 (one) Tax Invoice which includes all supplies to the same buyer of Taxable Goods and/or Taxable Service recipient for 1 (one) calendar month.
(2)	Tax Invoice referred to in paragraph (1) is referred to as a combined Tax Invoice.
(3)	The combined Tax Invoice referred to in paragraph (2) must be prepared no later than the end of the month of the supplies of Taxable Goods and/or Taxable Services.

Article 71
(1)	Tax Invoices prepared by Taxable Persons after a period of 3 (three) months from the time the Tax Invoice should be prepared as referred to in Article 69 paragraph (2) and Article 70 paragraph (3) are not treated as Tax Invoices.
(2)	Taxable Persons preparing the Tax Invoices referred to in paragraph (1) shall be deemed not to have prepared the Tax Invoices.
(3)	Taxable Persons referred to in paragraph (2) are subject to penalties pursuant to statutory provisions in the field of taxation.
(4)	VAT stated in the Tax Invoices referred to in paragraph (1) is non-creditable Input VAT.

Article 72
(1)	A Tax Invoice must include information on supplies of Taxable Goods and/or Taxable Services which at least contains:
	a.	the name, address and TIN of the supplier of Taxable Goods or Taxable Services;
	b.	the identity of the buyer of Taxable Goods or Taxable Service recipient which includes:
		1.	name, address and TIN, for resident taxpayers and government agencies;
		2.	name, address and TIN or national identification number, for individual tax residents pursuant to statutory provisions;
		3.	name, address and passport number, for individual non-tax residents; or
		4.	name and address, for corporate non-tax residents or non-tax subjects as referred to in Article 3 of the Income Tax Law;
	c.	the types of goods or Services, total selling price or considerations and discounts;
	d.	collected VAT;
	e.	collected Sales Tax on Luxury Goods;
	f.	code, serial number and preparation date of the Tax Invoice; and
	g.	the name and signature of the person entitled to sign the Tax Invoice.
(2)	National identification number referred to in paragraph (1) subparagraph b number 2 is equivalent to the TIN in the context of preparing Tax Invoices and Input VAT crediting.

Article 73
(1)	Tax Invoices referred to in Article 72 paragraph (1):
	a.	are in the electronic format;
	b.	are preparing using the application or system provided and/or stipulated by the Directorate General of Taxes; and
	c.	includes a signature in the form of an Electronic Signature.
(2)	Excluded from the provisions referred to in paragraph (1), Tax Invoices for:
	a.	supplies of Taxable Goods to individual foreign passport holders referred to in Article 16E of the VAT Law, prepared pursuant to statutory provisions in the field of taxation on procedures for the application and settlement of requests for the return of personal effects for foreign passport holders;
	b.	supplies of Taxable Goods and/or Taxable Services to buyers of Taxable Goods and/or Taxable Service recipients with the end consumer characteristics, prepared pursuant to the provisions under Article 13 paragraph (5a) of the VAT Law; and
	c.	supplies of Taxable Goods, supplies of Taxable Services, exports of Taxable Goods, exports of intangible Taxable Goods and/or exports of Taxable Services, in which the proof of VAT collection is in the form of certain documents equivalent to Tax Invoices, prepared pursuant to the provisions under Article 13 paragraph (6) of the VAT Law.

Article 74
(1)	Tax Invoices referred to in Article 73 paragraph (1) must:
	a.	be uploaded by Taxable Persons using the application or system provided and/or stipulated by the Directorate General of Taxes; and
	b.	obtain approval from the Directorate General of Taxes.
(2)	Tax Invoices in the electronic format that do not obtain approval from the Directorate General of Taxes referred to in paragraph (1) subparagraph b do not constitute Tax Invoices.
(3)	VAT listed in the Tax Invoices referred to in paragraph (2) is non-creditable Input VAT.

Article 75
Sales invoices issued by Taxable Persons are included in the definition of Tax Invoices referred to in Article 73 paragraph (1) insofar as:
1.	including information referred to in Article 72 paragraph (1);
2.	uploaded using the application or system provided and/or stipulated by the Directorate General of Taxes; and
3.	obtaining approval from the Directorate General of Taxes.

Article 76
(1)	Taxable Persons may prepare a replacement Tax Invoice for the Tax Invoice referred to in Article 73 paragraph (1) if there is an error in the completion or misspelling in the Tax Invoice, thereby, it does not contain correct, complete and clear information.
(2)	Taxable Persons may reprint the Tax Invoice if the printed Tax Invoice referred to in Article 73 paragraph (1) is damaged or lost.
(3)	Taxable Persons may request Tax Invoice data in the electronic format from the Directorate General of Taxes if the Tax Invoice data referred to in Article 73 paragraph (1) is damaged or lost.
(4)	Taxable Persons must cancel the Tax Invoice that has been prepared for supplies of:
	a.	Taxable Goods and/or Taxable Services of which the transactions are canceled; or
	b.	goods and/or services for which a Tax Invoice should not be prepared.

Article 77
(1)	In the event of certain circumstances that cause Taxable Persons to be unable to prepare a Tax Invoice in the electronic format as referred to in Article 73 paragraph (1), Taxable Persons are permitted to prepare a Tax Invoice in a non-electronic format.
(2)	Certain circumstances referred to in paragraph (1) are circumstances caused by wars, riots, revolutions, natural disasters, strikes, fires and other causes beyond the control of the Taxable Persons , as stipulated by the Director General of Taxes.

Article 78
(1)	Tax Invoices must be filled out correctly, completely and clearly.
(2)	Taxable Persons that prepare a Tax Invoice that does not comply with the provisions of paragraph (1) are subject to penalties pursuant to statutory provisions in the field of taxation.
(3)	VAT listed in the Tax Invoice referred to in paragraph (2) is non-creditable Input VAT.

Section Four Tax Invoices for Retailer Taxable Persons Supplying Taxable Goods and/or Taxable Services to Buyers with End Consumer Characteristics Article 79
(1)	Supplies of Taxable Goods and/or Taxable Services to buyers of Taxable Goods and/or Taxable Service recipients with the end consumer characteristics are retail supplies.
(2)	End consumer characteristics referred to in paragraph (1) include:
	a.	buyers of goods and/or service recipients that directly consume purchased or received goods and/or services; and
	b.	buyers of goods and/or service recipients that do not use or utilize purchased or received goods and/or services for business.
(3)	Taxable Persons whose entire or part of their business is supplying Taxable Goods and/or Taxable Services to buyers of Taxable Goods and/or Taxable Service recipients with the end consumer characteristics as referred to in paragraph (2), including those performed through Electronic Commerce, constitute retailer Taxable Persons .

Article 80
(1)	Retailer Taxable Persons referred to in Article 79 paragraph (3) may prepare a Tax Invoice for each of Taxable Goods and/or Taxable Services without specifying the buyer’s identity as referred to in Article 72 paragraph (1) subparagraph b and the seller’s name and signature as referred to in Article 72 paragraph (1) subparagraph g.
(2)	Tax Invoices referred to in paragraph (1) for supplies of Taxable Goods and/or Taxable Services to buyers of Taxable Goods and/or Taxable Service recipients with the end consumer characteristics referred to in Article 79 paragraph (2) must be prepared by including information which at least contains:
	a.	name, address and TIN of the supplier of Taxable Goods and/or Taxable Services;
	b.	the types of goods or services, total selling price or considerations and discounts;
	c.	collected VAT or VAT and Sales Tax on Luxury Goods; and
	d.	code, serial number and preparation date of the Tax Invoice.
(3)	Tax Invoices referred to in paragraph (2) may be in the form of cash receipts, sales invoices, cash register slips, tickets, receipts or proof of supplies of or other similar payments.
(4)	VAT or VAT and Sales Tax on Luxury Goods referred to in paragraph (2) subparagraph c may be included in the selling price or considerations or listed separately.
(5)	The code and the serial number of the Tax Invoices referred to in paragraph (2) subparagraph d may be self-determined according to the common business practice of the retailer Taxable Persons .
(6)	Tax Invoices referred to in paragraph (2) shall be prepared at least for:
	a.	buyers of Taxable Goods and/or Taxable Service recipients; and
	b.	the archive of retailer Taxable Persons .
(7)	Archive of retailer Taxable Persons referred to in paragraph (6) subparagraph b may be in the form of Tax Invoice records in the form of electronic media as a means of data storage.
(8)	Taxable Persons may prepare Tax Invoices referred to in paragraph (2) for:
	a.	personal use of Taxable Goods and/or Taxable Services that are not related to subsequent production activities or are used for activities that are not directly related to the said Taxable Persons ’ business; and
	b.	free of charge Taxable Goods and/or Taxable Services to buyers of Taxable Goods and/or Taxable Service recipients with the end consumer characteristics as referred to in Article 79 paragraph (2).
(9)	Retailer Taxable Persons may prepare the Tax Invoices referred to in paragraph (2) for supplies of Taxable Goods and/or Taxable Services eligible for the VAT non-collected or VAT exempt facilities.
(10)	VAT listed in the Tax Invoices referred to in paragraph (2) is non-creditable Input VAT.

Article 81
(1)	Excluded from the provisions referred to in Article 80 paragraph (2), Tax Invoices for supplies of certain Taxable Goods and/or certain Taxable Services to buyers of the Taxable Goods and/or Taxable Service recipients with the end consumer characteristics referred to in Article 79 paragraph (2) are prepared pursuant to the provisions of Article 73 paragraph (1).
(2)	Certain Taxable Goods referred to in paragraph (1) include:
	a.	land transportation in the form of motor vehicles;
	b.	water transportation in the form of cruise ships, excursion boats, ferries and/or yachts;
	c.	air transportation in the form of airplanes, helicopters and/or hot air balloons;
	d.	land and/or buildings; and
	e.	firearms and/or bullets.
(3)	Certain Taxable Services referred to in paragraph (1) include:
	a.	land transportation rental services in the form of motor vehicles;
	b.	water transportation rental services in the form of cruise ships, excursion boats, ferries and/or yachts;
	c.	air transportation rental services in the form of airplanes, helicopters and/or hot air balloons; and
	d.	land and/or building rental services.

Article 82
(1)	Tax Invoices referred to in Article 80 paragraph (2) must be filled out correctly, completely and clearly.
(2)	Retailer Taxable Persons that prepare Tax Invoices that do not comply with the provisions of paragraph (1) are subject to penalties pursuant to statutory provisions in the field of taxation.

CHAPTER IV GENERAL PROVISIONS AND TAX PROCEDURES Section One Procedures for Interest Compensation Article 83
(1)	Interest compensation related to Income Tax, VAT and Sales Tax on Luxury Goods are granted to Taxpayers in the event of:
	a.	a delay in tax refunds as referred to in Article 11 paragraph (3) of the General Provisions and Tax Procedures Law;
	b.	a delay in the issuance of the Notice of Tax Overpayment Assessment as referred to in Article 17B paragraph (3) of the General Provisions and Tax Procedures Law;
	c.	a delay in the issuance of the Notice of Tax Overpayment Assessment as referred to in Article 17B paragraph (4) of the General Provisions and Tax Procedures Law;
	d.	tax overpayment due to a filed objection, appeal or civil review that is granted in part or in whole as referred to in Article 27B paragraph (1) of the General Provisions and Tax Procedures Law; or
	e.	tax overpayment due to the Amendment Decision Letter, decision letter on the relief or cancellation of the notice of tax assessment or decision letter on the relief or cancellation of the Notice of Tax Collection that grants part or all of the Taxpayer’s application as referred to in Article 27B paragraph (3) of the General Provisions and Tax Procedures Law, except for:
		1.	tax overpayment due to the Amendment Decision Letter in respect of Mutual Agreement; or
		2.	tax overpayment due to the decision letter on the cancellation of the notice of tax assessment as referred to in Article 36 paragraph (1) subparagraph d of the General Provisions and Tax Procedures Law.
(2)	Interest compensation referred to in paragraph (1) subparagraph d shall be granted for the tax overpayment amounting to a maximum of the overpayment amount approved by the Taxpayer in the Closing Conference for the Tax Return stating the overpayment for which the following has been issued:
	a.	Notice of Tax Underpayment Assessment;
	b.	Notice of Additional Tax Underpayment Assessment;
	c.	Notice of Tax Overpayment Assessment; or
	d.	Notice of Nil Tax Assessment.
(3)	The overpayment amount approved by the Taxpayer in the Closing Conference referred to in paragraph (2) is the overpayment amount according to the Taxpayer submitted by the Taxpayer in the Closing Conference.
(4)	Tax Return stating an overpayment referred to in paragraph (2) is a Tax Return stating an overpayment with an application for tax refunds.
(5)	Interest compensation referred to in paragraph (1) subparagraph d shall not be granted to tax overpayment due to the issuance of an Objection Decision Letter, Appeal Decision or Civil Review Decision, which originates from payment of a Notice of Tax Underpayment Assessment or Notice of Additional Tax Underpayment Assessment, either approved or not approved by the Taxpayer in the Closing Conference.

Article 84
(1)	In the event of a delay in the refund of Land and Building Tax for the plantation sector, forestry sector, mining sector and other sectors, interest compensation in respect of Land and Building Tax shall be granted to the Taxpayer.
(2)	The delay in the refund of Land and Building Tax referred to in paragraph (1), is the result of the issuance of:
	a.	Decision Letter on the Land and Building Tax Overpayment;
	b.	Objection Decision;
	c.	Appeal Decision or Civil Review Decision;
	d.	Amendment Decision Letter;
	e.	Land and Building Tax Administrative Penalty Relief Decision Letter or Decision Letter on the Nullification of Land and Building Tax Administrative Penalties;
	f.	Decision Letter on the Reduction of Notice of Tax Due or Decision Letter on the Cancellation of Notice of Tax Due;
	g.	Decision Letter on the Reduction of Notice of Land and Building Tax Assessment or Decision Letter on the Cancellation of Land and Building Tax Assessment; or
	h.	Decision Letter on the Reduction of Notice of Land and Building Tax Collection or Decision Letter on the Cancellation of Notice of Land and Building Tax Collection.

Article 85
(1)	Interest compensation due to the delay in tax refunds referred to in Article 83 paragraph (1) subparagraph a is granted at a monthly interest rate stipulated by the Minister of Finance, of the amount of tax overpayment.
(2)	The number of months as the basis for the granting of interest compensation referred to in paragraph (1) is calculated from the end of the issuance deadline of the SKPKPP or SKPPIB until the issuance date of the SKPKPP or SKPPIB.
(3)	The issuance deadline of the SKPKPP or SKPPIB referred to in paragraph (2) is no later than 1 (one) month since:
	a.	the application for tax refunds is received in connection with the issuance of the Notice of Tax Overpayment Assessment referred to in Article 17 paragraph (1) of the General Provisions and Tax Procedures Law;
	b.	the issuance of the Notice of Tax Overpayment Assessment referred to in Article 17 paragraph (2) or Article 17B of the General Provisions and Tax Procedures Law;
	c.	the issuance of the Preliminary Tax Refund Decision Letter for Taxpayers with certain criteria referred to in Article 17C of the General Provisions and Tax Procedures Law, Taxpayers that fulfil certain requirements referred to in Article 17D of the General Provisions and Tax Procedures Law and low-risk Taxable Persons referred to in Article 9 paragraph (4c) of the VAT Law;
	d.	the issuance of the Objection Decision Letter, Amendment Decision Letter, Administrative Penalty Relief Decision Letter, Administrative Penalty Nullification Decision Letter, decision letter on the relief or cancellation of the notice of tax assessment, decision letter on the relief or cancellation of the Notice of Tax Collection or SKPIB, which results in a tax overpayment; or
	e.	the Appeal Decision or Civil Review Decision is received by the office of the Directorate General of Taxes authorised to implement the Court’s Decision, which results in a tax overpayment.
(4)	Interest compensation referred to in paragraph (1) is granted for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month.
(5)	The monthly interest rate referred to in paragraph (1) is the interest rate in effect on the date the calculation of interest compensation commences.

Article 86
(1)	Interest compensation due to the delay in the issuance of Notice of Tax Overpayment Assessment referred to in Article 83 paragraph (1) subparagraph b is granted at the monthly interest rate stipulated by the Minister of Finance, of the amount of tax overpayment.
(2)	The number of months as the basis for the granting of interest compensation referred to in paragraph (1) is calculated from the end of the 1 (one) month period for the issuance of a Notice of Tax Overpayment Assessment that complies with the provisions under Article 17B paragraph (2) of the General Provisions and Tax Procedures Law until the issuance of the Notice of Tax Overpayment Assessment.
(3)	Interest compensation referred to in paragraph (1) is granted for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month.
(4)	The monthly interest rate referred to in paragraph (1) is the interest rate in effect on the date the calculation of interest compensation commences.

Article 87
(1)	Interest compensation due to the delay in the issuance of Notice of Tax Overpayment Assessment referred to in Article 83 paragraph (1) subparagraph c is granted at the monthly interest rate stipulated by the Minister of Finance, of the amount of tax overpayment.
(2)	The number of months as the basis for the granting of interest compensation referred to in paragraph (1) is calculated from the end of the period of 12 (twelve) months from the date on which the application letter for tax refunds is completely received until the issuance of the Notice of Tax Overpayment Assessment.
(3)	Interest compensation referred to in paragraph (1) is granted for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month.
(4)	The monthly interest rate referred to in paragraph (1) is the interest rate in effect on the date the calculation of interest compensation commences.

Article 88
(1)	Interest compensation for tax overpayment due to the filing of an objection, appeal or application for a civil review related to the Tax Return stating overpayment referred to in Article 83 paragraph (1) subparagraph d is granted at the monthly interest rate stipulated by the Minister of Finance, of the amount of tax overpayment.
(2)	The number of months as the basis for the granting of interest compensation referred to in paragraph (1) is calculated from the issuance date of the Notice of Tax Underpayment Assessment, Notice of Additional Tax Underpayment Assessment, Notice of Tax Overpayment Assessment or Notice of Nil Tax Assessment until the issuance of Objection Decision Letter or the pronouncement of Appeal Decision or Civil Review Decision.
(3)	Interest compensation referred to in paragraph (1) is granted for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month.
(4)	The monthly interest rate referred to in paragraph (1) is the interest rate in effect on the date the calculation of interest compensation commences.

Article 89
(1)	Interest compensation on tax overpayment due to Amendment Decision Letter, decision letter on the relief or cancellation of the notice of tax assessment or decision letter on the relief or cancellation of the Notice of Tax Collection, referred to in Article 83 paragraph (1) subparagraph e is granted at the monthly interest rate stipulated by the Minister of Finance, of the amount of tax overpayment.
(2)	The number of months as the basis for the granting of interest compensation referred to in paragraph (1) is calculated from:
	a.	the payment date of the Notice of Tax Underpayment Assessment or the Notice of Additional Tax Underpayment Assessment until the issuance date of the Amendment Decision Letter or decision letter on the relief or cancellation of the notice of tax assessment; or
	b.	the issuance date of the Notice of Tax Overpayment Assessment or Notice of Nil Tax Assessment until the issuance date of the Amendment Decision Letter or decision letter on the relief or cancellation of the notice of tax assessment; or
	c.	the payment date of the Notice of Tax Collection until the issuance date of the Amendment Decision Letter or decision letter on the relief or cancellation of the Notice of Tax Collection.
(3)	Interest compensation referred to in paragraph (1) is granted for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month.
(4)	The monthly interest rate referred to in paragraph (1) is the interest rate in effect on the date the calculation of interest compensation commences.

Article 90
(1)	Interest compensation due to the delay in the refund of Land and Building Tax referred to in Article 84 is granted at the monthly interest rate stipulated by the Minister of Finance, of the amount of tax overpayment.
(2)	The number of months as the basis for the granting of interest compensation referred to in paragraph (1) is calculated from the end of the issuance deadline of the Land and Building Tax SKPKPP ends the issuance date of the Land and Building Tax SKPKPP.
(3)	The issuance deadline of the Land and Building Tax SKPKPP referred to in paragraph (2) is no later than 1 (one) month since:
	a.	the issuance of the Land and Building Tax Overpayment Decision Letter;
	b.	the issuance of the Objection Decision;
	c.	the receipt of the Appeal Decision or Civil Review Decision by the office of the Directorate General of Taxes authorised to implement the Appeal Decision or Civil Review Decision;
	d.	the issuance of the Amendment Decision Letter;
	e.	the issuance of the Land and Building Tax Administrative Penalty Relief Decision Letter or Decision Letter on the Nullification of Land and Building Tax Administrative Penalties;
	f.	the issuance of the Decision Letter on the Reduction of Notice of Tax Due or Decision Letter on the Cancellation of Notice of Tax Due;
	g.	the issuance of the Decision Letter on the Reduction of Notice of Land and Building Tax Assessment or Decision Letter on the Cancellation of Land and Building Tax Assessment; or
	h.	the issuance of the Decision Letter on the Reduction of Notice of Land and Building Tax Collection or the Decision Letter on the Cancellation of Notice of Land and Building Tax Collection.
(4)	Interest compensation referred to in paragraph (1) is granted for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month.
(5)	The monthly interest rate referred to in paragraph (1) is the interest rate in effect on the date the calculation of interest compensation commences.

Article 91
(1)	In the event that there is interest compensation as referred to in Article 83, the Taxpayer shall apply for the granting of interest compensation to the Head of the Tax Office where the Taxpayer is registered or where the Taxable Person is registered.
(2)	In the event that there is interest compensation as referred to in Article 84, the Taxpayer shall apply for the granting of interest compensation to the Head of the Tax Office where the Land and Building Tax object is administered.
(3)	The application referred to in paragraph (1) or paragraph (2) is submitted:
	a.	electronically, through certain channels stipulated by the Director General of Taxes; or
	b.	in writing,
	by including the Taxpayer’s domestic account number.
(4)	Application in writing referred to in paragraph (3) subparagraph b is submitted:
	a.	in person;
	b.	by post with proof of mail delivery; or
	c.	through a shipping company or courier services with proof of postage.

Article 92
(1)	Director General of Taxes issues an SKPIB if the application for interest compensation referred to in Article 91 paragraph (1) or Article 91 paragraph (2):
	a.	fulfils the provisions under Article 83 or Article 84; and
	b.	includes the Taxpayer’s domestic account number referred to in Article 91 paragraph (3).
(2)	Interest Compensation Decision Letter referred to in paragraph (1) in respect of the granting of interest compensation on tax overpayment due to the filing of an objection, appeal or civil review referred to in Article 83 paragraph (1) subparagraph d, may be issued if:
	a.	for the Objection Decision Letter, an appeal is not filed to the Tax Court;
	b.	the Appeal Decision has been received by the office of the Directorate General of Taxes authorised to grant interest compensation; or
	c.	the Civil Review Decision has been received by the office of the Directorate General of Taxes which is authorised to grant interest compensation.
(3)	In the event that the SKPIB is not issued because the application for interest compensation referred to in Article 91 paragraph (1) or Article 91 paragraph (2) does not fulfil the provisions referred to in paragraph (1) and paragraph (2), the Director General of Taxes issues a notification that the SKPIB is not issued to the Taxpayer.
(4)	SKPIB referred to in paragraph (1) or the notification that the SKPIB is not issued referred to in paragraph (3) is issued no later than 1 (one) month after the application for interest compensation is completely received by the Tax Office.
(5)	The provisions on the format of the SKPIB referred to in paragraph (1) are listed in Appendix XX which constitutes an integral part of this Ministerial Regulation.
(6)	The provisions on the format of the notification that the SKPIB is not issued referred to in paragraph (3) are listed in Appendix XXI which constitutes an integral part of this Ministerial Regulation.
(7)	Interest Compensation Decision Letter referred to in paragraph (1) is issued based on the tax calculation memo of interest compensation, which contains the calculation of the amount of interest compensation granted to the Taxpayer.
(8)	The provisions on the format of the tax calculation memo of interest compensation referred to in paragraph
(7)	are listed in Appendix XXII which constitutes an integral part of this Ministerial Regulation.
(9)	For Taxpayers that have obtained a permit to maintain bookkeeping in English and United States Dollars, interest compensation in respect of tax payable in United States Dollars are granted in Rupiah, which is calculated using the exchange rate stipulated by the Minister of Finance in effect upon:
	a.	the issuance of the Notice of Tax Overpayment Assessment as referred to in Article 17B of the General Provisions and Tax Procedures Law;
	b.	the issuance of the Objection Decision Letter or pronouncement of the Appeal Decision or Civil Review Decision;
	c.	the issuance of the Amendment Decision Letter;
	d.	the issuance of the decision letter on the relief or cancellation of the notice of tax assessment; or
	e.	the issuance of the decision letter on the relief or cancellation of the Notice of Tax Collection.

Article 93
(1)	The granting of interest compensation to a Taxpayer must be set off in advance against the Tax Liability administered at the Tax Office where the Taxpayer is registered and/or where the Taxable Person is registered, including at the Tax Office where the branch Taxpayer is registered and the Tax Office where Land and Building Tax objects are administered.
(2)	Tax Liability referred to in paragraph (1) includes:
	a.	for a Taxable Period, a Fraction of a Tax Year or the 2007 Tax Year and earlier are the Tax Liability of Income Tax, VAT and Sales Tax on Luxury Goods listed in:
		1.	the Notice of Tax Collection;
		2.	the Notice of Tax Underpayment Assessment or Notice of Additional Tax Underpayment Assessment;
		3.	the Amendment Decision Letter, Objection Decision Letter, Appeal Decision as well as Civil Review Decision, resulting in an increase in the amount of tax payable; and/or
		4.	the Amendment Decision Letter, Objection Decision Letter, Appeal Decision as well as Civil Review Decision, resulting in tax refunds that should not otherwise be refunded;
	b.	for a Taxable Period, a Fraction of a Tax Year or the 2008 Tax Year onwards is Tax Liability of Income Tax, VAT and Sales Tax on Luxury Goods listed in:
		1.	the Notice of Tax Collection;
		2.	the Notice of Tax Underpayment Assessment or Notice of Additional Tax Underpayment Assessment for the amount approved by the Taxpayer in the Closing Conference;
		3.	the Notice of Tax Underpayment Assessment or Notice of Additional Tax Underpayment Assessment for the amount not approved by the Taxpayer Closing Conference, for which:
			a)	no objection is filed;
			b)	an objection is filed but the Objection Decision Letter partially grants, rejects or increases the amount of tax payable and for the Objection Decision Letter, no appeal is filed; or
			c)	an appeal is filed and for the Objection Decision Letter, an appeal is filed but the Appeal Decision partially grants, increases the amount of tax payable or rejects;
		4.	the Objection Decision Letter for which no objection is filed;
		5.	the Amendment Decision Letter resulting in an increase in the amount of tax payable;
		6.	the Appeal Decision or Civil Review Decision, resulting in an increase in the amount of tax payable; and/or
		7.	the Amendment Decision Letter, Objection Decision Letter, Appeal Decision as well as Civil Review Decision, resulting in tax refunds that should not otherwise be refunded;
	c.	Tax Liability of Land and Building Tax listed in:
		1.	the Notice of Land and Building Tax Collection;
		2.	the Notice of Tax Due;
		3.	the Notice of Land and Building Tax Assessment;
		4.	the Objection Decision, Appeal Decision or Civil Review Decision, resulting in an increase in the amount of tax payable;
		5.	the Amendment Decision Letter resulting in an increase in the amount of tax payable; and/or
		6.	the Amendment Decision Letter, Objection Decision, Appeal Decision as well as Civil Review Decision, resulting in tax refunds that should not otherwise be refunded.
(3)	In the event that after the calculation referred to in paragraph (1) is carried out, there is residual interest compensation that must be paid to the Taxpayer, based on the Taxpayer’s application, the residual interest compensation may be set off against:
	a.	tax that will be payable on behalf of the Taxpayer; and/or
	b.	Tax Liability and/or tax that will be payable on behalf of another Taxpayer.

Article 94
(1)	Calculation of interest compensation against the Tax Liability and/or tax that will be payable referred to in Article 93 is stated in the tax calculation memo of interest compensation.
(2)	The provisions on the format of the tax calculation memo of interest compensation referred to in paragraph (1) are listed in Appendix XXIII which constitutes an integral part of this Ministerial Regulation.
(3)	The SKPPIB is issued based on the tax calculation memo of interest compensation referred to in paragraph (1).
(4)	The provisions on the format of the SKPPIB referred to in paragraph (3) are listed in Appendix XXIV which constitutes an integral part of this Ministerial Regulation.
(5)	Settlement of Tax Liability and/or tax that will be payable through the calculation of the residual interest compensation referred to in Article 93 is recognised upon the issuance of the SKPPIB.

Article 95
(1)	The calculation of interest compensation against Tax Liability and/or tax that will be payable referred to in Article 93 is followed up with the set-off against the Tax Liability and/or tax that will be payable.
(2)	In the event that there is no Tax Liability and/or tax that will be payable, all interest compensation is granted to the Taxpayer concerned.
(3)	The set-off against the Tax Liability and/or tax that will be payable referred to in paragraph (1) shall be carried out through Interest Compensation Payment withholding.
(4)	Interest Compensation Payment withholding referred to in paragraph (3) is considered valid if an NTPN or a revenue reference number has been obtained pursuant to statutory provisions in the field of treasury.

Article 96
(1)	Based on the SKPPIB referred to in Article 94 paragraph (3), the Head of the Tax Office on behalf of the Minister of Finance issues an Interest Compensation Payment Orde.
(2)	In the event of an error in the issuance of the Interest Compensation Payment Orde referred to in paragraph (1), the Head of the Tax Office on behalf of the Minister of Finance amends the Interest Compensation Payment Orde insofar as the SP2D has not been issued.
(3)	The provisions on the format of the Interest Compensation Payment Orde referred to in paragraph (1) are listed in Appendix XXV which constitutes an integral part of this Ministerial Regulation.
(4)	Interest Compensation Payment Orde referred to in paragraph (1) is prepared in 4 (four) copies, with the following designation:
	a.	copy 1 and copy 2 for the KPPN;
	b.	copy 3 for the Taxpayer; and
	c.	copy 4 for the archive of the Tax Office.
(5)	The SKPPIB and the Interest Compensation Payment Orde as well as Computer Data Archiving are submitted to the KPPN.

Article 97
(1)	Based on the Interest Compensation Payment Orde referred to in Article 96 paragraph (1), the Head of the KPPN on behalf of the Minister of Finance issues a SP2D provided that:
	a.	in the event that all interest compensation is set off against the Tax Liability and/or tax that will be payable through Interest Compensation Payment withholding, the Head of the KPPN issues a Nil SP2D;
	b.	in the event that there is residual interest compensation that must be given to the Taxpayer after being set off against the Tax Liability and/or tax that will be payable through Interest Compensation Payment withholding, the Head of the KPPN issues an SP2D according to the Taxpayer’s account listed in the Interest Compensation Payment Orde; or
	c.	in the event that all interest compensation is granted to the Taxpayer, the Head of the KPPN issues an SP2D according to the Taxpayer’s account stated in the Interest Compensation Payment Orde.
(2)	Head of the KPPN issues state revenue receipts in the event that interest compensation is set off against the Tax Liability and/or tax that will be payable through Interest Compensation Payment withholding.
(3)	The KPPN submits:
	a.	SP2D list;
	b.	copy 2 of the Interest Compensation Payment Orde; and
	c.	state revenue receipts, in the event there is interest compensation set off against the Tax Liability and/or tax that will be payable through Interest Compensation Payment withholding,
	to the Tax Office issuing the Interest Compensation Payment Orde.

Article 98
State revenue receipt for Interest Compensation Payment withholding shall be submitted by the Tax Office issuing the Interest Compensation Payment Orde to the Taxpayer.

Article 99
(1)	SKPPIB referred to in Article 94 paragraph (3) and the Interest Compensation Payment Orde referred to in Article 96 paragraph (1) is issued no later than 1 (one) month after the issuance of the SKPIB.
(2)	The SP2D referred to in Article 97 paragraph (1) is issued by the Head of the KPPN pursuant to statutory provisions in the field of treasury.

Article 100
(1)	The official authorised to sign the SKPPIB and Interest Compensation Payment Orde submits a signature specimen to the Head of the KPPN at the beginning of each fiscal year.
(2)	In the event of a change in the official authorised to sign the SKPPIB and Interest Compensation Payment Orde, the substitute official must submit a signature specimen to the Head of the KPPN from the time the person concerned takes office.

Article 101
Payment of interest compensation is part of tax revenue deductibles.

Article 102
Director General of Taxes issues the Notice of Tax Collection referred to in Article 14 paragraph (1) subparagraph h of the General Provisions and Tax Procedures Law to collect interest compensation that should not otherwise be granted to a Taxpayer in the event that a decision is issued, a decision is received or data or information is found, indicating the existence of interest compensation that should not be otherwise be granted to the Taxpayer.

Section Two Procedures for the Payment and Remittance of Taxes Article 103
Several provisions in the Minister of Finance Regulation Number 242/PMK.03/2014 concerning Procedures for the Payment and Remittance of Taxes (Official Gazette of the Republic of Indonesia of 2014 Number 1973), are amended as follows:

1.	The provisions of number 1, number 2, number 3, number 4, number 15, number 16, number 17, number 21, number 22, number 23 and number 25 of Article 1 are amended, thereby, Article 1 reads as follows:

	Article 1
	Referred to herein this Minister of Finance Regulation:
	1.	General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	2.	Income Tax Law, hereinafter referred to as the PPh Law, is Law Number 7 of 1983 concerning Income Tax as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	3.	Value Added Law, hereinafter referred to as the VAT Law, is Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	4.	Stamp Duty Law is Law Number 10 of 2020 concerning Stamp Duty.
	5.	Land and Building Tax Law, hereinafter referred to as the PBB Law, is Law Number 12 of 1985 concerning Land and Building Tax as amended by Law Number 12 of 1994.
	6.	Income Tax, hereinafter abbreviated to PPh, is Income Tax referred to in the Income Tax Law.
	7.	Value Added Tax, hereinafter referred to as VAT, is Value Added Tax referred to in the VAT Law.
	8.	Sales Tax on Luxury Goods, hereinafter referred to as STLGs, is Sales Tax on Luxury Goods referred to in the VAT Law.
	9.	Stamp Duty is a tax on documents referred to in the Stamp Duty Law.
	10.	Land and Building Tax, hereinafter abbreviated to Land and Building Tax, is the tax referred to in the Land and Building Tax Law.
	11.	Taxpayer Identification Number, hereinafter abbreviated to TIN, is a number issued to Taxpayers as a means of tax administration that is used as a personal identity or Taxpayer identity in conducting their tax rights and obligations.
	12.	Taxable Period is a period used as the basis for a Taxpayer to calculate, remit and file taxes payable in a certain period as stipulated by the General Provisions and Tax Procedures Law.
	13.	Tax Year is a period of 1 (one) calendar year unless a Taxpayer adopts an accounting year that is different from the calendar year.
	14.	Taxable Object Number, hereinafter abbreviated to NOP, is the identification number of a taxable object as a means of tax administration.
	15.	State Treasury is a place for storing state money stipulated by the Minister of Finance as the State General Treasurer to accommodate all state revenues and pay state expenditures.
	16.	State Revenue Module, hereinafter abbreviated to MPN is a revenue module that contains a series of procedures ranging from the receipt, remittance, data collection, recording, summarisation to reporting in respect of State Revenues and is an integrated system with the State Treasury and Budget System.
	17.	Bank for Revenue Collection is a commercial bank appointed by the Proxy of State General Treasurer to receive remittances of State Revenue.
	18.	Foreign Exchange Bank for Revenue Collection is a commercial bank appointed by the Minister of Finance to receive state revenue remittances in the context of exports of and imports.
	19.	Foreign Currency Bank for Revenue Collection is a foreign exchange bank appointed by the State General Treasurer/Proxy of State General Treasurer to receive remittances of State Revenue in foreign currency.
	20.	Post Office for Revenue Collection is a Post Office appointed by the Proxy of State General Treasurer to receive State Revenue remittances.
	21.	State Revenue Transaction Number, hereinafter abbreviated to NTPN, is the number of proof of payment or remittance to the state treasury issued through the state revenue module or by the state revenue system managed by the Directorate General of Treasury.
	22.	Bank Transaction Number, hereinafter abbreviated to NTB, is the number of proof of remittance of State Revenues issued by a Bank for Revenue Collectionor Foreign Currency Bank for Revenue Collection.
	23.	Postal Transaction Number, hereinafter abbreviated to NTP, is the number of proof remittance of State Revenues issued by a Post Office for Revenue Collection.
	24.	Withholding Receipt Number, hereinafter abbreviated to NPP, is the number of state revenue receipt transactions originating from Payment Order withholding.
	25.	State Revenue Receipt, hereinafter abbreviated to BPN, is a document issued by a Collecting Agent for State Revenue transactions, that includes the NTPN and Bank Transaction Number/Postal Transaction Number/Other Taxpayment Institution Transaction Number as other administrative means equivalent to a payment slip.
	26.	Tax Payment Slip, hereinafter abbreviated to SSP, is a receipt of tax payment or remittance using a specific form or other means to the state treasury, through a place of payment appointed by the Minister of Finance.
	27.	Customs, Excise, and Tax Payment Slip in the context of imports, hereinafter referred to as SSPCP, is a payment slip for state revenues in the context of imports in the form of import duties, administrative fines, other customs revenues, excise, other excise revenues, employment services, interest and Import Article 22 Income Tax, Import VAT as well as Sales Tax on Imported Luxury Goods.
	28.	Overbooking is a process of overbooking tax revenues to be recorded in the appropriate tax revenues.
	29.	Overbooking Receipt, hereinafter referred to as Pbk Receipt, is receipt that shows that an Overbooking has been carried out.

2.	The provisions of paragraph (1), paragraph (3), paragraph (4), and paragraph (7) of Article 7 are amended, and 1 (one) paragraph is added to Article 7, namely paragraph (11), thereby, Article 7 reads as follows:

	Article 7
	(1)	For small-scale business Taxpayers and Taxpayers in certain regions, the settlement period referred to in Article 6 paragraph (1) may be extended to a maximum of 2 (two) months.
	(2)	Small-scale business Taxpayers referred to in paragraph (1) consist of individual Taxpayers and corporate Taxpayers.
	(3)	Small-scale business individual Taxpayers referred to in paragraph (2) must fulfil the following criteria:
		a.	receiving income from a business, excluding income from services in connection with independent personal services; and
		b.	having a gross turnover not exceeding IDR4,800,000,000.00 (four billion and eight hundred million rupiah) in 1 (one) Tax Year.
	(4)	Small-scale business corporate Taxpayers referred to in paragraph (2) must fulfill the following criteria:
		a.	Corporate Taxpayers excluding PEs; and
		b.	receiving income from a business with a gross turnover not exceeding IDR4,800,000,000.00 (four billion and eight hundred million rupiah) in 1 (one) Tax Year.
	(5)	To obtain an extension of the settlement period referred to in paragraph (1), small-scale business Taxpayers or Taxpayers in certain regions must apply for an extension of the settlement period to the Director General of Taxes, no later than 9 (nine) working days prior to the payment due date using an application letter for an extension of the settlement period.
	(6)	Based on the application of the Taxpayer referred to in paragraph (5), the Director General of Taxes issues a decision within 7 (seven) working days after the date the application is received.
	(7)	The decision referred to in paragraph (6) is in the form of:
		a.	approval; or
		b.	rejection of the Taxpayer's application.
	(8)	In the event that the Taxpayer’s application is approved as referred to in paragraph (7) subparagraph a, the Director General of Taxes issues a decision on the approval of the extension of the tax settlement period.
	(9)	In the event that the Taxpayer's application is rejected as referred to in paragraph (7) subparagraph b, the Director General of Taxes issues a decision on the rejection of the extension of the tax settlement period.
	(10)	If the period of 7 (seven) working days referred to in paragraph (6) has elapsed and the Director General of Taxes does not issue a decision, the Taxpayer’s application is deemed accepted.
	(11)	The approval decision referred to in paragraph (10) must be issued no later than 5 (five) working days after the 7 (seven) working day period ends.

3.	Between paragraph (6) and paragraph (7) of Article 14, 2 (two) paragraphs are inserted, namely paragraph (6a) and paragraph (6b), thereby, Article 14 reads as follows:

	Article 14
	(1)	Tax payment and remittance shall be carried out in Rupiah currency.
	(2)	Excluded from the provisions referred to in paragraph (1), Taxpayers that have obtained a permit to maintain bookkeeping in English and in United States Dollar currency shall pay Article 25 Income Tax, Article 29 Income Tax and Final Income Tax self-paid by the Taxpayers as well as the notice of tax assessment and Notice of Tax Collection issued in United States Dollar currency, using United States Dollar currency.
	(3)	Included in the definition of a Taxpayer that has obtained a permit to maintain bookkeeping in English and in United States Dollar currency referred to in paragraph (2) is a Taxpayer that submits written notification of bookkeeping in English and United States Dollar currency as stipulated under statutory provisions in the field of taxation.
	(4)	Payment of tax in United States Dollar referred to in paragraph (2) shall be made to the state treasury through a Foreign Currency Bank for Revenue Collection.
	(5)	Taxpayers referred to in paragraph (2) may pay Article 25 Income Tax, Article 29 Income Tax and Final Income Tax self-paid by the Taxpayer in Rupiah.
	(6)	In the event that the tax payment is made in Rupiah currency as referred to in paragraph (5), the Taxpayer must convert the payment into Rupiah currency to United States Dollar currency using the exchange rate stipulated in the applicable Minister of Finance Decree on the payment date.
	(6a)	In the event that the payment referred to in paragraph (2) is made through a Disbursement of Refund Claim deduction, the payment shall be made in Rupiah using the exchange rate stipulated in the Decree of the Minister of Finance in effect on the issuance date of the SKPKPP.
	(6b)	In the event that the payment referred to in paragraph (2) is made through Interest Compensation Payment withholding, the payment shall be made in Rupiah using the exchange rate stipulated in the Minister of Finance Decree in effect on the issuance date of the SKPPIB.
	(7)	The provisions on procedures for the payment of Income Tax in United States Dollar currency are stipulated by the Director General of Taxes Regulation or the Director General of Treasury Regulation, either jointly or individually according to their respective authorities.

4.	The provisions of Article 21 are amended, thereby, it reads as follows:

	Article 21
	(1)	Taxpayer’s application referred to in Article 20 must be submitted using an application letter for payment of tax instalments or an application letter for deferral of tax payment.
	(2)	The application letter referred to in paragraph (1) shall be signed by the Taxpayer and if it is signed by a non-Taxpayer, a special power of attorney must be attached as stipulated under statutory laws and regulations in the field of taxation.
	(3)	The application letter referred to in paragraph (1) includes:
		a.	the amount of tax liability for which the payment is requested to be paid in instalments, the instalment period and the amount of instalments; or
		b.	the amount of tax liability for which payment is requested to be deferred and the deferral period.
	(4)	The application letter referred to in paragraph (1) shall be attached with the reasons and evidence of the liquidity crisis or circumstances beyond the control of the Taxpayers as referred to in Article 20 in the form of interim financial statements, financial statements or notes on gross turnover or revenues and/or gross income.
	(5)	In the event that a Taxpayer applies for instalment or deferral of the payment of outstanding Land and Building Tax as referred to in Article 5, in addition to fulfilling the requirements referred to in paragraph (1), paragraph (2), paragraph (3) and paragraph (4), the Taxpayer must not have Land and Building Tax arrears from the previous year and the application must also be attached with a copy of the Notice of Tax Due, Notice of Land and Building Tax Assessment or Notice of Land and Building Tax Collection for which the application for instalment or deferral is submitted.
	(6)	Application letter for instalment of tax payment or application letter for tax payment deferral referred to in paragraph (1) shall be submitted no later than:
		a.	the time the Annual Tax Return is filed, for the tax underpayment referred to in Article 3; and/or
		b.	before the Distress Warrant is notified by the Tax Bailiff to the Tax Bearer as stipulated in statutory provisions on tax collection using a distress warrant, for the tax payable referred to in Article 5 and outstanding tax referred to in Article 6 paragraph (1).
	(7)	The application letter referred to in paragraph (1) shall be submitted:
		a.	electronically, through certain channels stipulated by the Director General of Taxes; or
		b.	in writing.
	(8)	Application in writing referred to in paragraph (7) subparagraph b is submitted:
		a.	in person;
		b.	by post with proof of postage; or
		c.	through a shipping company or courier services with proof of postage.

5.	The provisions of Article 22 are amended, thereby, it reads as follows:

	Article 22
	(1)	Taxpayers applying for instalments or deferral of tax payments as referred to in Article 20, must provide tangible assets as collateral, with the following criteria:
		a.	the tangible assets belong to the applicant Tax Bearer as evidenced by proof of ownership of the tangible assets; and
		b.	the tangible assets are not being used as collateral for the applicant Tax Bearer’s liabilities.
	(2)	Taxpayers applying for instalments after the time limit referred to in Article 21 paragraph (6) must provide tangible assets as collateral as referred to in paragraph (1) in the amount of tax liability for which the application for instalment of tax payments is submitted.

6.	The provisions of paragraph (1) of Article 23 are amended, thereby, Article 23 reads as follows:

	Article 23
	(1)	After examining the completeness of the application referred to in Article 21 paragraph (1), paragraph (2), paragraph (3), paragraph (4), paragraph (5) and the period for submitting the application as referred to in Article 21 paragraph (6) and after considering the collateral referred to in Article 22, the Director General of Taxes issues a decision within 7 (seven) working days after the date the application is received.
	(2)	The decision referred to in paragraph (1) may be in the form of:
		a.	approval of the amount of tax instalments and/or the instalment period or the length of the deferral according to the Taxpayer’s application;
		b.	approval of a fraction of the tax instalment amount and/or the instalment period or the length of the deferral requested by the Taxpayer; or
		c.	rejection of the Taxpayer’s application.
	(3)	In the event that the Taxpayer’s application is approved as referred to in paragraph (2) subparagraph a or partially approved as referred to in paragraph (2) subparagraph b, the Director General of Taxes issues a decision on the approval of the instalment of tax payments or a decision on the approval of the deferral of tax payments.
	(4)	In the event that the Taxpayer's application is rejected as referred to in paragraph (2) subparagraph c, the Director General of Taxes shall issue a decision on the rejection of instalments/deferral of tax payments.
	(5)	If the period of 7 (seven) working days referred to in paragraph (1) has elapsed and the Director General of Taxes does not issue a decision, the application is approved according to the Taxpayer’s application and the decision on the approval of the instalment of tax payments or the decision on the approval of the deferral of tax payments must be issued no later than 5 (five) working days after the 7 (seven) working day period ends.

7.	The provisions of Article 25 are amended, thereby, it reads as follows:

	Article 25
	(1)	instalments for tax underpayment referred to in Article 3, tax payable referred to in Article 5 or outstanding tax referred to in Article 6 paragraph (1), may be provided for:
		a.	a maximum of 24 (twenty-four) months from the issuance of the decision on the approval of the instalment of tax payments referred to in Article 23 paragraph (3) or paragraph (5) with instalments of a maximum of 1 (one) time in 1 (one) month, for application for outstanding tax instalments referred to in Article 6 paragraph (1);
		b.	a maximum of 24 (twenty-four) months from the issuance of the decision on the approval of the instalment of tax payments referred to in Article 23 paragraph (3) or paragraph (5) with instalments of a maximum 1 (one) time in 1 (one) month, for application for tax instalment payable referred to in Article 5; or
		c.	a maximum of the filing deadline for the Annual Income Tax Return in the following Tax Year, with instalments of a maximum of 1 (one) time in 1 (one) month, for application for instalments for tax underpayment based on the Annual Income Tax Return referred to in Article 3.
	(2)	Deferral of tax underpayment referred to in Article 3, tax payable referred to in Article 5 or outstanding tax referred to in Article 6 paragraph (1) may be granted for:
		a.	a maximum of 24 (twenty-four) months from the issuance of the decision on approval for deferral of tax payment referred to in Article 23 paragraph (3) or paragraph (5), for applications for deferral of outstanding tax referred to in Article 6 paragraph (1);
		b.	a maximum of 24 (twenty-four) months from the issuance of the decision on the approval of the deferral of tax payment referred to in Article 23 paragraph (3) or paragraph (5), for application for deferment of payable taxes referred to in Article 5; or
		c.	no later than the filing deadline for the Annual Income Tax Return in the following Tax Year, for application for deferral of tax underpayment based on the Annual Income Tax Return referred to in Article 3.

8.	The provisions of Article 30 are amended, thereby, it reads as follows:

	Article 30
	(1)	In the event that a Taxpayer is approved to install or defer the payment as referred to in Article 23 paragraph (2) subparagraph a and subparagraph b and the approval is not related to the Notice of Tax Collection, Notice of Tax Due, Notice of Land and Building Tax Assessment and Notice of Land and Building Tax Collection, the Taxpayer is subject to administrative penalties in the form of interest at the monthly rate stipulated by the Minister of Finance of the amount of outstanding tax and imposed for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month as referred to in Article 19 paragraph (2) of the General Provisions and Tax Procedures Law, which is calculated from the payment due date until the instalment payment/settlement.
	(2)	In the event that a Taxpayer is approved to install or defer the payment as referred to in Article 23 paragraph (2) subparagraph a and subparagraph b and the approval is related to the Notice of Tax Due, Notice of Land and Building Tax Assessment, and Notice of Land and Building Tax Collection, the Taxpayer is subject to an administrative fine of 2% (two per cent) a month as referred to in Article 11 paragraph (3) of the Land and Building Tax Law which is calculated from the due date until the payment day for a maximum of 24 (twenty-four) months.

9.	Appendix III referred to in Article 32 paragraph (3) is amended to be AS listed in Appendix XXVI which constitutes an integral part of this Ministerial Regulation.

Section Three Tax Returns Article 104
Several provisions in the Minister of Finance Regulation Number 243/PMK.03/2014 concerning Tax Returns (Official Gazette of the Republic of Indonesia of 2014 Number 1974) as amended by Minister of Finance Regulation Number 9/PMK.03/2018 concerning Amendments to the Minister of Finance Regulation Number 243/PMK.03/2014 concerning Tax Returns (Official Gazette of the Republic of Indonesia of 2018 Number 180), are amended as follows:

1.	The provisions of number 1, number 2 and number 3 of Article 1 are amended, thereby, Article 1 reads as follows:

	Article 1
	Referred to herein this Ministerial Regulation:
	1.	General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	2.	Income Tax Law, hereinafter referred to as the PPh Law, is Law Number 7 of 1983 concerning Income Tax as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	3.	Value Added Law, hereinafter referred to as the VAT Law, is Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	4.	Income Tax, hereinafter abbreviated to PPh, is Income Tax referred to in the Income Tax Law.
	5.	Value Added Tax, hereinafter abbreviated to VAT, is Value Added Tax referred to in the VAT Law.
	6.	Sales Tax on Luxury Goods, hereinafter abbreviated to STLGs, is Sales Tax on Luxury Goods referred to in the VAT Law
	7.	Taxpayer is any individual or entity, comprising taxpayer and withholding agent having tax rights and obligations pursuant to statutory tax provisions.
	8.	Tax Return, hereinafter abbreviated to SPT, is a form used by a Taxpayer to file the calculation and/or payment of taxes, taxable objects and/or non-taxable objects and/or assets and liabilities pursuant to statutory provisions in the field of taxation.
	9.	Annual Tax Return is a Tax Return for a Tax Year or a Fraction of a Tax Year.
	10.	Periodic Tax Return is a Tax Return for a Taxable Period.
	11.	A shipping company or courier services are a company in the form of a legal entity that provides certain types of mail delivery services, including the delivery of Tax Returns to the Directorate General of Taxes.
	12.	Examination of the Receipt of Tax Return, hereinafter referred to as Tax Return Examination, is a series of activities carried out to assess the completeness of Tax Return completion and its attachments.

2.	The provisions of paragraph (5) and paragraph (6) of Article 20 are amended, thereby, Article 20 reads as follows:

	Article 20
	(1)	Taxpayers may voluntarily amend the Tax Return that has been filed by submitting a written statement, provided that the Director General of Taxes has not submitted:
		a.	the Notice of Audit; or
		b.	the Notice of Public Preliminary Audit to the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member.
	(2)	The written statement in the amendment to the Tax Return referred to in paragraph (1) is prepared by providing a sign in the space provided in the Tax Return stating that the Taxpayer concerned has amended the Tax Return.
	(3)	In the event that the amendment to the Tax Return referred to in paragraph (1) states a loss or overpayment, the amendment to the Tax Return must be submitted no later than 2 (two) years prior to the statute of limitation of the assessment.
	(4)	In the event that the Taxpayer receives a notice of tax assessment, Objection Decision Letter, Amendment Decision Letter, Appeal Decision or Civil Review Decision of the previous Tax Year or several preceding Tax Years, which states a diferrent tax loss from the set off tax loss In the Annual Tax Return to be amended, the Taxpayer may amend the Annual Tax Return as referred to in paragraph (1) within a period of 3 (three) months after receiving the notice of tax assessment, Objection Decision Letter, Amendment Decision Letter, Appeal Decision or Civil Review Decision.
	(5)	In the event that Taxpayers self-amend Annual Tax Return which results in a larger tax liability, they are subject to administrative penalties in the form of interest at the monthly interest rate stipulated by the Minister of Finance of the amount of tax due and is imposed for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month as referred to in Article 8 paragraph (2) of the General Provisions and Tax Procedures Law.
	(6)	In the event Taxpayers self-amend Periodic Tax Return which results in a larger tax liability, they are subject to administrative penalties in the form of interest at the monthly interest rate stipulated by the Minister of Finance of the amount of tax due and is imposed for a maximum of 24 (twenty-four) months and part of the month is calculated as 1 (one) full month as referred to in Article 8 paragraph (2a) of the General Provisions and Tax Procedures Law.

Section Four Procedures for Audits Article 105
Several provisions in the Minister of Finance Regulation Number 17/PMK.03/2013 concerning Procedures for Audits (Official Gazette of the Republic of Indonesia of 2013 Number 47) as amended by the Minister of Finance Regulation Number 184/PMK.03/2015 concerning Amendments to Minister of Finance Regulation Number 17/PMK.03/2013 concerning Procedures for Audits (Official Gazette of the Republic of Indonesia of 2015 Number 1468), are amended as follows:

1.	Provisions of number 1 of Article 1 are amended, thereby, Article 1 reads as follows:

	Article 1
	Referred to herein this Ministerial Regulation:
	1.	General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	2.	Audit is a series of activities to collect and process data, information and/or evidence conducted in an objective and professional manner based on auditing standards to assess tax compliance in fulfilling tax obligations and/or for other purposes to implement statutory tax provisions.
	3.	Field Audit is an Audit conducted at a Taxpayer’s residence or domicile, the Taxpayer’s place of business or independent personal services and/or other places deemed necessary by the tax auditors.
	4.	Office Audit is an Audit conducted at the office of the Directorate General of Taxes.
	5.	Tax Auditor is a Civil Servant within the Directorate General of Taxes or a professional appointed by the Director General of Taxes, who is given the authority and responsibility to carry out the Audit.
	6.	Tax Auditor Identification is identification issued by the Director General of Taxes constituting proof that the person whose name is listed on the identification card is a Tax Auditor.
	7.	Audit Order, hereinafter abbreviated to SP2, is a warrant to conduct an Audit to assess compliance with the fulfilment of tax obligations and/or for other purposes to implement statutory tax provisions.
	8.	Notice of Field Tax Audit is a notice concerning the implementation of a Field Audit to assess compliance with the fulfilment of tax obligations and/or for other purposes to implement statutory tax provisions.
	9.	Summons for an Office Audit is a summons regarding the conduct of an Office Audit to assess compliance with the fulfilment of tax obligations and/or for other purposes to implement statutory tax provisions.
	10.	Bookkeeping is a recording process conducted regularly to collect data and financial information including assets, liabilities, capital, income and expenses, and acquisition price and sales of goods or services resulting in financial statements in the form of a balance sheet and income statement for such a Tax Year.
	11.	Electronically managed data is data in electronic form, which is generated by a computer and/or other electronic data processors and stored in diskettes, compact disks, backup tapes, hard disks or other electronic storage media.
	12.	Books of Accounts, Records and Documents Storage Places are places organised by Taxpayers, archives or document storage companies and/or those organised by other parties.
	13.	Sealing is the act of placing a seal in a certain premises or room as well as movable and/or immovable property which are used or reasonably suspected to be used as a place or tool to store books of accounts or records, documents, including electronically managed data and other objects.
	14.	Audit Working Paper, hereinafter abbreviated to KKP, is a detailed and clear record prepared by the Tax Auditors concerning Audit procedures, data, information and/or collected evidence, performed tests and conclusions drawn in respect of the Audit implementation.
	15.	Notice of Tax Audit Findings, hereinafter abbreviated to SPHP, is a letter containing Audit findings which include corrected accounts, correction values, basis for correction, temporary calculation of the principal amount of tax payable and temporary calculation of administrative
	16.	Closing Conference is a conference between the Taxpayer and the Tax Auditors on Audit findings, the results of which are stated in the official report of closing conference which is signed by both parties and contain corrections to the principal tax payable, either those approved or disapproved and the calculation of administrative penalties.
	17.	Audit Quality Assurance Team is a team established by the Director General of Taxes to discuss Audit findings that are limited to the legal basis for corrections that have not been agreed upon between the Tax Auditors and the Taxpayer in the Closing Conference to produce a quality Audit.
	18.	Audit Findings Report, hereinafter abbreviated to LHP, is a report containing the implementation and findings of an Audit compiled by the Tax Auditor in a concise and clear manner and pursuant to the scope and objectives of the Audit.
	19.	Summary of Audit Findings Report, hereinafter referred to as Summary of LPHP, is a report on the termination of the Audit without any proposed issuance of a notice of tax assessment.
	20.	Preliminary Audit is an Audit conducted to find Preliminary Evidence of whether an alleged Tax Crime has occurred.
	21.	Re-Audit is an Audit conducted on a Taxpayer for whom a notice of tax assessment has been issued based on prior Audit findings for the same type of tax and Taxable Period, a Fraction of a Tax Year or Tax Year.
	22.	Audit Questionnaire is a form containing a number of questions and assessments by the Taxpayer in respect of the implementation of an Audit.
	23.	Risk Analysis is an activity carried out to assess the level of Taxpayers’ non-compliance at risk of causing a loss of potential tax revenues.

2.	The provisions of paragraph (1) of Article 4 are amended and between paragraph (1) and paragraph (2) of Article 4, 1 (one) paragraph is inserted, namely paragraph (1a), thereby, Article 4 reads as follows:

	Article 4
	(1)	An audit to assess the compliance with the fulfilment of tax obligations referred to in Article 2, is carried out if the following criteria are fulfilled:
		a.	Taxpayers applying for tax refunds as referred to in Article 17B of the General Provisions and Tax Procedures Law;
		b.	there is concrete data that causes the tax payable to be unpaid or underpaid;
		c.	the Taxpayers file a Tax Return stating overpayment, other than those applying for tax refunds as referred to in subparagraph a;
		d.	the Taxpayers that have been granted preliminary tax refunds;
		e.	the Taxpayers file a Tax Return stating a loss;
		f.	the Taxpayers perform a merger, consolidation, spin-off, liquidation, dissolution or will leave Indonesia for good;
		g.	the Taxpayers change the accounting year or bookkeeping method or due to the revaluation of fixed assets;
		h.	the Taxpayers do not file or file the Tax Return but past the period specified in the reprimand letter selected to be Audited based on the Risk Analysis;
		j.	the Taxable Persons have not performed supplies of Taxable Goods and/or Taxable Services and/or exports of Taxable Goods and/or Taxable Services and have been granted Input VAT refunds or have credited Input VAT as referred to in Article 9 paragraph (6e) of the 1984 Value Added Tax Law and the amendments thereto.
	(1a)	Concrete data referred to in paragraph (1) subparagraph b is data obtained or held by the Director General of Taxes in the form of:
		a.	result of clarification or confirmation of tax invoices;
		b.	Withholding Tax receipt;
		c.	tax data in respect of Taxpayers that do not file the Tax Return within the period referred to in Article 3 paragraph (3) of the General Provisions and Tax Procedures Law and after being reprimanded in writing, the Tax Return is not filed on time as specified in the Reprimand Letter; and/or
		d.	proof of transaction or tax data that can be used to calculate the Taxpayers’ tax liabilities.
	(2)	The provisions on Risk Analysis referred to in paragraph (1) subparagraph h and subparagraph i are implemented pursuant to statutory provisions.

3.	The provisions of paragraph (2), paragraph (3), and paragraph (4) of Article 5 are amended, thereby, Article 5 reads as follows:

	Article 5
	(1)	The Audit to assess compliance with the fulfilment of tax obligations referred to in Article 4 is carried out in a Field Audit or Office Audit.
	(2)	Audit with the criteria referred to in Article 4 paragraph (1) subparagraph a is carried out in the form of an Office Audit, in the event that the application for tax refunds is submitted by a Taxpayer that fulfils the following requirements:
		a.	the Taxpayer's financial statement for the audited Tax Year is audited by a public accountant or the financial statement of one of the Tax Years of the 2 (two) Tax Years before the audited Tax Year has been audited by a public accountant with an unqualified opinion; and
		b.	the Taxpayer is not being subject to Preliminary Audits, Investigations or Tax Crime Prosecution and/or the Taxpayer in the last 5 (five) years have never been sentenced for a tax crime.
	(3)	Audits with the criteria referred to in Article 4 paragraph (1) subparagraph b is conducted in the form of an Office Audit.
	(4)	Audits with the criteria referred to in Article 4 paragraph (1) subparagraph c to subparagraph g and subparagraph j are conducted in the form of an Office Audit or a Field Audit.
	(5)	Audits with the criteria referred to in Article 4 paragraph (2) subparagraph h and subparagraph i are conducted in the form of a Field Audit.
	(6)	In the event that in an Office Audit, indications of transactions related to transfer pricing and/or other special transactions are found indicating the existence of manipulation of financial transactions, the implementation of the Office Audit is changed to a Field Audit.

4.	The provisions of Article 11 are amended, thereby, it reads as follows:

	Article 11
	In conducting an Audit to assess compliance with the fulfilment of tax obligations, Tax Auditors must:
	a.	submit a Notice of Field Audit to the Taxpayer in the event that the Audit is conducted with a Field Audit type or a Summons for an Office Audit in the event that the Audit is conducted in the form of an Office Audit;
	b.	show the Tax Auditor Identification and Audit Order to the Taxpayer when conducting the Audit;
	c.	show a letter containing changes to the Tax Auditor team to the Taxpayer if the membership structure of the Tax Auditor team changes;
	d.	hold a meeting with the Taxpayer to explain:
		1)	the reasons and objectives of the Audit;
		2)	the Taxpayer’s rights and obligations during and after the Audit;
		3)	the Taxpayer’s right to apply for a conference with the Audit Quality Assurance Team in the event that there are Audit findings that are limited to the legal basis for corrections that have not been agreed upon between the Tax Auditors and the Taxpayer in the Closing Conference, except for Audits of concrete data conducted in Office Audits as referred to in Article 5 paragraph (3); and
		4)	the Taxpayer’s obligation to fulfil the request for books of accounts, records and/or documents constituting the basis for the bookkeeping or recording and other documents, which are borrowed from the Taxpayer;
	e.	outline the results of the meeting referred to in subparagraph d in the official report of meeting with the Taxpayers;
	f.	submit the Notice of Tax Audit Findings to the Taxpayers;
	g.	grant the right to attend to the Taxpayers in the context of the Closing Conference at the specified time;
	h.	submit the Audit Questionnaire to the Taxpayers;
	i.	guide the Taxpayers in fulfilling their tax obligations pursuant to statutory tax provisions by submitting written advice;
	j.	return books of accounts, records and/or documents constituting the basis for bookkeeping or recording and other documents borrowed from the Taxpayers; and
	k.	keeping the confidentiality of everything that is known or notified to them by the Taxpayers in the context of the Audit from other ineligible parties.

5.	The provisions of Article 13 are amended, thereby, it reads as follows:

	Article 13
	In the implementation of an Audit to assess compliance with the fulfilment of tax obligations, the Taxpayers are entitled to:
	a.	ask the Tax Auditors to show the Tax Auditor Identification and Audit Order;
	b.	ask the Tax Auditors to provide a Notice of Field Audit in the event that the Audit is conducted in a Field Audit;
	c.	ask the Tax Auditors to show a letter outlining changes to the Tax Auditor team if the membership structure of the Tax Auditor team changes;
	d.	ask the Tax Auditors to explain the reasons and objectives of the Audit;
	e.	receive the Notice of Tax Audit Findings;
	f.	attend the Closing Conference at the specified time;
	g.	apply for a discussion with the Audit Quality Assurance Team, in the event that there are Audit findings that are limited to the legal basis for corrections that have not been agreed upon between the Tax Auditors and the Taxpayer in the Closing Conference, except for Audits of concrete data conducted in the form of an Office Audit as referred to in Article 5 paragraph (3); and
	h.	provide an opinion or assessment on the implementation of the Audit by the Tax Auditors by completing the Audit Questionnaire.

6.	The provisions of paragraph (4), paragraph (5) and paragraph (6) of Article 15 are amended, thereby, Article 15 reads as follows:

	Article 15
	(1)	Audits to assess compliance with the fulfilment of tax obligations are conducted within the Audit period that includes:
		a.	the assessment period; and
		b.	the Closing Conference and reporting period.
	(2)	If an Audit is conducted in the form of a Field Audit, the assessment period referred to in paragraph (1) subparagraph a is a maximum of 6 (six) months, which is calculated from the time the Notice of Field Audit is submitted to the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member, until the date the Notice of Tax Audit Findings is submitted to the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member.
	(3)	If an Audit is conducted in the form of an Office Audit, the assessment period referred to in paragraph (1) subparagraph a is a maximum of 4 (four) months, which is calculated from the date the Taxpayer, the Taxpayer’s the Taxpayer’s representative, attorney, employee or adult family member fulfils the Summons for an Office Audit until the date the Notice of Tax Audit Findings is submitted to the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member.
	(4)	If an Audit of concrete data is conducted in the form of an Office Audit as referred to in Article 5 paragraph (3), the assessment period referred to in paragraph (1) subparagraph a is a maximum of 1 (one) month, which is calculated from the date the Taxpayer, the Taxpayer’s representative or attorney appears to fulfil the Summons for an Office Audit until the date the Notice of Tax Audit Findings is submitted to the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member.
	(5)	The Closing Conference and reporting period referred to in paragraph (1) subparagraph b is a maximum of 2 (two) months, calculated from the date the Notice of Tax Audit Findings is submitted to the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member until the date of the Audit Findings Report.
	(6)	If the Audit of concrete data is conducted in the form of an Office Audit as referred to in Article 5 paragraph (3), the Closing Conference and reporting period referred to in paragraph (1) subparagraph b is a maximum of 10 (ten) working days, calculated from the date of Notice of Tax Audit Findings is submitted to the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member until the date of the Audit Findings Report.

7.	Provisions of paragraph (1) of Article 17 are amended, thereby, Article 17 reads as follows:

	Article 17
	(1)	The assessment period of the Office Audit referred to in Article 15 paragraph (3), may be extended for a maximum of 2 (two) months, except for the Audit of concrete data conducted in the form of an Office Audit as referred to in Article 5 paragraph (3) cannot be extended.
	(2)	Assessment period of the Office Audit referred to in paragraph (1) is extended in the event that:
		a.	the Office Audit is extended to another Taxable Period, a Fraction of a Tax Year or Tax Year;
		b.	there is a confirmation or request for data and/or information to a third party;
		c.	the scope of the Office Audit covers all types of taxes; and/or
		d.	based on the consideration of the head of the Audit implementing unit.

8.	Provisions of Article 21 are amended, thereby, it reads as follows:

	Article 21
	An Audit is completed by preparing a Summary of Audit Findings Report as referred to in Article 20 subparagraph a in the event that:
	a.	the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member being audited
		1)	is not found within 6 (six) months from the date the Notice of Field Audit is issued; or
		2)	does not fulfil the Audit summons within a period of 4 (four) months from the date the Summons for an Office Audit is issued;
	b.	the Field Audit or Office Audit is suspended because it is followed up with a public Preliminary Audit and the public Preliminary Audit:
		1)	does not proceed with an investigation because the Taxpayers disclose the untruth of their actions as referred to in Article 8 paragraph (3) of the General Provisions and Tax Procedures Law;
		2)	deleted;
		3)	proceeds with an investigation but the investigation is terminated because there is no prosecution as referred to in Article 44B of the General Provisions and Tax Procedures Law;
		4)	proceeds with an investigation but the investigation is terminated because the statute of limitation for the event has elapsed as referred to in Article 44A of the General Provisions and Tax Procedures Law; or
		5)	proceeds with an investigation and prosecution and there has been a Court Decision concerning a tax crime with permanent legal force stating that the Taxpayer is legally and convincingly proven guilty of committing a tax crime and a copy of the Court Decision has been received by the Director General of Taxes;
	c.	the Field Audit or Office Audit is suspended because it is followed up with an investigation as a follow-up to the restricted Preliminary Audits and the investigation:
		1)	is terminated as it fulfils provisions referred to in Article 44B of the General Provisions and Tax Procedures Law; or
		2)	proceeds with prosecution and there has been a Court Decision concerning a tax crime with permanent legal force stating that the Taxpayer is legally and convincingly proven guilty of committing a tax crime and a copy of the Court Decision has been received by the Director General of Taxes; or
	d.	The Re-Audit does not result in an additional tax that has been stipulated in the previous notice of tax assessment.

9.	Between Article 21 and Article 22 1 (one) article is inserted, namely Article 21A, thereby, it reads as follows:

	Article 21A
	Excluded from the provisions referred to in Article 21 subparagraph b number 1), subparagraph b number 3), and subparagraph c number 1), an Audit is completed by preparing an Audit Findings Report as referred to in Article 20 subparagraph b, in the event that based on the results of Preliminary Audits or the results of tax crime investigations, there remains a tax overpayment.

10.	The provisions of paragraph (1) and paragraph (3) of Article 22 are amended, thereby, Article 22 reads as follows:

	Article 22
	(1)	Audit completed by preparing an Audit Findings Report as referred to in Article 20 subparagraph b, is carried out in the event that:
		a.	the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member being Audited is found or fulfils the Audit summons and the Audit can be completed within the Audit period;
		b.	the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member being Audited is found or fulfils the Audit summons and the assessment of compliance with the fulfilment of tax obligations cannot be completed until:
			1)	the end of the extension of the Field Audit assessment period referred to in Article 16 paragraph (1) or paragraph (3); or
			2)	the end of the extension of the Office Audit assessment period referred to in Article 17 paragraph (1);
		c.	the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member being Audited in respect of the application for tax refunds referred to in Article 17B of the General Provisions and Tax Procedures Law:
			1)	is not found within 6 (six) months from the date the Notice of Field Audit is issued; or
			2)	does not fulfil the Audit summons within a period of 4 (four) months from the date the Summons for an Office Audit is issued;
		d.	the Taxpayer, the Taxpayer’s representative, attorney, employee or adult family member being Audited for concrete data in an Office Audit as referred to in Article 5 paragraph (3) does not fulfil the Audit summons within 1 (one) month from the date the Summons for an Office Audit is issued;
		e.	the Field Audit or Office Audit is suspended because it is followed up with a public Preliminary Audit and the public Preliminary Audit:
			1)	is terminated because the individual Taxpayer subject to the public Preliminary Audit passes away;
			2)	is terminated because there is no preliminary evidence of a tax crime;
			3)	proceeds with an investigation but the investigation is terminated because there is insufficient evidence or the event is not a tax crime or the suspect passes away referred to in Article 44A of the General Provisions and Tax Procedures Law; or
			4)	proceeds with an investigation and prosecution and there has been a Court Decision concerning a tax crime with permanent legal force with a verdict of not guilty or released from all charges and a copy of the Court Decision has been received by the Director General of Taxes;
			or
		f.	the Field Audit or Office Audit is suspended because it is followed up with an investigation as a follow-up to the restricted Preliminary Audits and the investigation:
			1)	is terminated because there is insufficient evidence or the event is not a tax crime or the suspect passes away as referred to in Article 44A of the General Provisions and Tax Procedures Law; or
			2)	proceeds with prosecution and there has been a Court concerning a tax crime with permanent legal force with a verdict of not guilty or released from all charges and a copy of the Court Decision has been received by the Director General of Taxes.
	(2)	Field Audit or Office Audit for which the assessment has not been completed as referred to in paragraph (1) subparagraph b, must be completed by submitting the Notice of Tax Audit Findings within a maximum period of 7 (seven) working days from the end of:
		a.	the extension of the Field Audit assessment period referred to in Article 16 paragraph (1) or paragraph (3); or
		b.	the extension of the Office Audit assessment period referred to in Article 17 paragraph (1), and proceeds to the Audit stage until the preparation of the Audit Findings Report.
	(3)	If the Taxpayer, the Taxpayer’s representative or attorney being Audited on concrete data in in the form of an Office Audit as referred to in Article 5 paragraph (3) does not fulfil the Audit summons, the Audit must be completed by submitting the Notice of Tax Audit Findings within a maximum period of 3 (three) working days after the statute of limitation of the 1 (one) month period referred to in paragraph (1) subparagraph d.

11.	The provisions of paragraph (5) of Article 41 are amended, thereby, Article 41 reads as follows:

	Article 41
	(1)	The findings of the Audit to assess compliance with the fulfilment of tax obligations must be notified to the Taxpayer through the submission of Notice of Tax Audit Findings which is attached with the list of Audit findings.
	(2)	Notice of Tax Audit Findings and the list of Audit findings referred to in paragraph (1) shall be submitted by the Tax Auditors in person or by facsimile.
	(3)	In the event that the Notice of Tax Audit Findings is submitted in person and the Taxpayer, the Taxpayer’s representative or attorney refuses to receive the Notice of Tax Audit Findings, the Taxpayer, the Taxpayer’s representative or attorney must sign a letter of refusal to receive the Notice of Tax Audit Findings.
	(4)	In the event that the Taxpayer, representative, or the Taxpayer's attorney refuses to sign the letter of refusal to receive the Notice of Tax Audit Findings referred to in paragraph (3), the Tax Auditors shall prepare an official report on refusal to receive the Notice of Tax Audit Findings which is signed by the Tax Auditor Team
	(5)	In the event that the Audit of concrete data is conducted in an Office Audit as referred to in Article 5 paragraph (3), the Notice of Tax Audit Findings referred to in paragraph (1) shall be submitted simultaneously with the submission of a written invitation to attend the Closing Conference.

12.	The provisions of paragraph (5) Article 42 are amended, thereby, Article 42 reads as follows:

	Article 42
	(1)	Taxpayers must provide a written response to the Notice of Tax Audit Findings and the list of Audit findings referred to in Article 41 paragraph (1) in the form of:
		a.	audit finding approval statement sheet in the event that the Taxpayer approves all Audit findings; or
		b.	rebuttal letter, in the event that the Taxpayer does not approve part or all of Audit findings.
	(2)	The written response referred to in paragraph (1) must be submitted within a maximum period of 7 (seven) working days from the date the Notice of Tax Audit Findings is received by the Taxpayer.
	(3)	Taxpayers may extend the submission period of the written response referred to in paragraph (2) for a maximum period of 3 (three) working days since the period referred to in paragraph (2) ends.
	(4)	To extend the submission period of the response referred to in paragraph (3), the Taxpayers must submit written notice before the period referred to in paragraph (2) ends.
	(5)	In the event that the Audit of concrete data is conducted in the form of an Office Audit as referred to in Article 5 paragraph (3), the written response referred to in paragraph (1) is submitted no later than the time the Taxpayer must fulfill the written invitation to attend the Closing Conference and the Taxpayer cannot extend the submission period of the written response.
	(6)	The written response referred to in paragraph (1) and written notice referred to in paragraph (4) are submitted by the Taxpayer in person or by facsimile.
	(7)	In the event that the Taxpayer does not submit a written response to the Notice of Tax Audit Findings, the Tax Auditors prepare an official report on non-submission of a written response to the Notice of Tax Audit Findings which is signed by the Tax Auditor team.

13.	The provisions of paragraph (4) of Article 43 are amended, thereby, Article 43 reads as follows:

	Article 43
	(1)	To carry out the discussion on Audit findings stated in the Notice of Tax Audit Findings and the list of Audit findings referred to in Article 41 paragraph (1), the Taxpayer must be given the right to attend the Closing Conference.
	(2)	The right to attend referred to in paragraph (1), is granted by sending a written invitation to the Taxpayer by stating the day and date of the Closing Conference.
	(3)	The invitation referred to in paragraph (2) must be submitted to the Taxpayer within a maximum period of 3 (three) working days as of:
		a.	the receipt of the written response to the Notice of Tax Audit Findings from the Taxpayer according to the period referred to in Article 42 paragraph (2) or paragraph (3); or
		b.	the end of the period referred to in Article 42 paragraph (3), in the event that the Taxpayer does not submit a written response to the Notice of Tax Audit Findings.
	(4)	If the Audit of concrete data is conducted in the form of an Office Audit as referred to in Article 5 paragraph (3), a written invitation to attend the Closing Conference is submitted together with the submission of the Notice of Tax Audit Findings.
	(5)	The invitation referred to in paragraph (2) may be submitted by the Tax Auditors in person or by facsimile.

14.	The provisions of paragraph (1) and paragraph (3) of Article 61 are amended, thereby, Article 61 reads as follows:

	Article 61
	(1)	Taxpayers may disclose in a separate report in writing the incorrect completion of the Tax Return that has been filed according to the actual situation referred to in Article 8 paragraph (4) of the General Provisions and Tax Procedures Law and Article 8 of Government Regulation Number 74 of 2011 and the amendments thereto insofar as that the Tax Auditors have not submitted the Notice of Tax Audit Findings.
	(2)	Disclosure of the incorrect completion of the Tax Return referred to in paragraph (1) shall be submitted to the Tax Office where the Taxpayer is registered.
	(3)	The separate report in writing referred to in paragraph (1) must be signed by the Taxpayer, the Taxpayer’s representative or attorney and attached with:
		a.	the calculation of underpaid tax according to the actual situation in the format of the Tax Return;
		b.	the Tax Payment Slip for the payment of underpaid tax; and
		c.	the Tax Payment Slip for the payment of administrative penalties in the form of interest as referred to in Article 8 paragraph (5) of the General Provisions and Tax Procedures Law.
	(4)	If the disclosure of incorrect Tax Return completion referred to in paragraph (1) does not result in a tax underpayment, the disclosure does not need to be attached with the Tax Payment Slip.

15.	The provisions of paragraph (5) Article 62 is amended and paragraph (7) Article 62 is deleted, thereby, Article 62 reads as follows:

	Article 62
	(1)	To prove the disclosure of untruth in a separate report as referred to in Article 61 paragraph (1), the Audit will continue and based on Audit findings, a notice of tax assessment is issued by considering the separate report and taking into account the paid tax principal.
	(2)	In the event that the Audit findings referred to in paragraph (1) prove that the disclosure of incorrect completion of the Tax Return by the Taxpayer is not in accordance with the actual situation, a notice of tax assessment is issued according to the actual situation.
	(3)	In the event that the Audit findings referred to in paragraph (1) prove that the disclosure of incorrect completion of the Tax Return by the Taxpayer is in accordance with the actual situation, a notice of tax assessment is issued according to the Taxpayer’s disclosure.
	(4)	The Tax Payment Slip referred to in Article 61 paragraph (3) subparagraph b is calculated as a tax credit in the notice of tax assessment issued based on the Audit findings referred to in paragraph (1), paragraph (2) and paragraph (3).
	(5)	Tax Payment Slip referred to in Article 61 paragraph (3) subparagraph c constitutes proof of payment of administrative penalties in the form of interest as referred to in Article 8 paragraph (5) of the General Provisions and Tax Procedures Law in respect of the disclosure of incorrect completion of the Tax Return.
	(6)	Notice of tax assessment referred to in paragraph (2) is added with administrative penalties pursuant to Article 13 of the General Provisions and Tax Procedures Law.
	(7)	Deleted.

16.	The provisions of paragraph (1) and paragraph (5) of Article 64 are amended, thereby, Article 64 reads as follows:

	Article 64
	(1)	In the event that the proposed public Preliminary Audit referred to in Article 63 paragraph
	(1)	is approved by the competent authority, the Audit implementation is suspended by preparing a report on the progress of the Audit until:
		a.	the public Preliminary Audit is completed because the Taxpayer discloses the untruth of actions as referred to in Article 8 paragraph (3) of the General Provisions and Tax Procedures Law;
		b.	deleted;
		c.	the public Preliminary Audit is terminated because the individual Taxpayer subject to the public Preliminary Audit passes away;
		d.	the public Preliminary Audit is terminated because no preliminary evidence of a tax crime is found;
		e.	the investigation is terminated pursuant to the provisions under Article 44A of the General Provisions and Tax Procedures Law or Article 44B of the General Provisions and Tax Procedures Law; or
		f.	the Court Decision on the tax crime already has permanent legal force and a copy of the Court Decision has been received by the Director General of Taxes.
	(2)	Audit suspension referred to in paragraph (1) must be notified in writing to the Taxpayer.
	(3)	The written notification referred to in paragraph (2) shall be submitted together with the submission of the notification of the public Preliminary Audit.
	(4)	Books of accounts, records and documents related to the suspended Audit referred to in paragraph (1) shall be submitted to the preliminary auditor by preparing an official report signed by the Tax Auditors and the preliminary auditor.
	(5)	A copy of the official report referred to in paragraph (4) shall be submitted to the Taxpayer.

17.	The provisions of paragraph (1) and paragraph (2) of Article 65 are amended and 1 (one) paragraph is added to Article 65, namely paragraph (3) thereby, Article 65 reads as follows:

	Article 65
	(1)	The suspended Audit referred to in Article 64 paragraph (1) shall proceed pursuant to applicable provisions, if:
		a.	the public Preliminary Audit is terminated because the individual Taxpayer subject to the public Preliminary Audit passes away;
		b.	the public Preliminary Audit is terminated because no preliminary evidence of a tax crime is found;
		c.	the public Preliminary Audit proceeds with an investigation but the investigation is terminated because there is insufficient evidence or the event is not a tax crime, or the suspect passes away as referred to in Article 44A of the General Provisions and Tax Procedures Law; or
		d.	the public Preliminary Audit proceeds with an investigation and prosecution and there has been a Court Decision with permanent legal force with a verdict of not guilty or released from all charges and a copy of the Court Decision has been received by the Director General of Taxes.
	(2)	The suspended Audit referred to in Article 64 paragraph (1) is terminated by preparing the Summary of Audit Findings Report referred to in Article 21 subparagraph b, if:
		a.	the public Preliminary Audit is completed because the Taxpayers disclose the untruth of their actions as referred to in Article 8 paragraph (3) of the General Provisions and Tax Procedures Law;
		b.	deleted;
		c.	the public Preliminary Audit proceeds with an investigation but the investigation is terminated because there is no prosecution as referred to in Article 44B of the General Provisions and Tax Procedures Law;
		d.	the public Preliminary Audit proceeds with an investigation but the investigation is terminated because the statute of limitation of the event has elapsed as referred to in Article 44A of the General Provisions and Tax Procedures Law; and
		e.	the public Preliminary Audit proceeds with an investigation and prosecution and there has been a Court Decision on a tax crime with permanent legal force stating that the Taxpayer is legally and convincingly proven guilty of committing a tax crime and a copy of the Court Decision has been received by the Director General of Taxes.
	(3)	Excluded from the provisions referred to in paragraph (2) subparagraph a and subparagraph c, the suspended audit referred to in Article 64 proceeds in the event that there remains tax overpayment based on preliminary audit results or investigation results.

18.	The provisions of paragraph (4) and paragraph (5) of Article 66 are amended and (one) paragraph is added to Article 66 namely paragraph (6), thereby, Article 66 reads as follows:

	Article 66
	(1)	In the event that the Taxpayer is Audited to assess compliance with the fulfilment of tax obligations is also subject to a restricted Preliminary Audit, the Audit to assess compliance with the fulfilment of tax obligations is suspended by preparing a progress report on the Audit if the restricted Preliminary Audits is followed up with an investigation.
	(2)	The Audit to assess compliance with the fulfilment of tax obligations referred to in paragraph (1) is suspended until:
		a.	the investigation is terminated pursuant to Article 44A or Article 44B of the General Provisions and Tax Procedures Law; or
		b.	the Court Decision on a tax crime with permanent legal force and a copy of the decision has been received by the Director General of Taxes.
	(3)	Audit suspension referred to in paragraph (1) must be notified in writing to the Taxpayer.
	(4)	The suspended Audit referred to in paragraph (1) proceeds if:
		a.	the investigation is terminated because there is insufficient evidence or the event is not a tax crime or the suspect passes away as referred to in Article 44A of the General Provisions and Tax Procedures Law; or
		b.	the investigation proceeds with prosecution and Court Decisions on a tax crime with permanent legal force with a verdict of not guilty or released from all charges and a copy of the Court Decision has been received by the Director General of Taxes.
	(5)	The suspended Audit referred to in paragraph (1) is terminated if:
		a.	the investigation is terminated due to Article 44B of the General Provisions and Tax Procedures Law;
		b.	the investigation is terminated because the statute of limitation of event has elapsed as referred to in Article 44A of the General Provisions and Tax Procedures Law; or
		c.	the investigation proceeds with prosecution and Court Decision on a tax crime permanent legal force other than that referred to in paragraph (4) subparagraph b and a copy of the Court Decision has been received by the Director General of Taxes.
	(6)	Excluded from the provisions referred to in paragraph (5) subparagraph a, the suspended Audit referred to in Article 64 proceeds in the event that remains tax overpayment based on investigation results.

19.	The provisions of paragraph (1) of Article 67 are amended, thereby, Article 67 reads as follows:

	Article 67
	(1)	In the event of a proceeded Audit as referred to in Article 65 paragraph (1) and paragraph (3) or Article 66 paragraph (4) and paragraph (6), the assessment period referred to in Article 15 or the extended assessment period referred to in Article 16 or Article 17 is extended for a maximum period of 4 (four) months.
	(2)	In the event that the Audit is terminated as referred to in Article 65 paragraph (2) or Article 66 paragraph (5), the Tax Auditors must submit a notice of termination of the Audit to the Taxpayer.
	(3)	The Director General of Taxes may continue the Audit if after the Audit is terminated as referred to in Article 65 paragraph (2) or Article 66 paragraph (5), there are data other than those disclosed in Article 8 paragraph (3) of the General Provisions and Tax Procedures Law or Article 44B of the General Provisions and Tax Procedures Law.

Section Five Procedures for the Issuance of the Notice of Tax Assessment and Notice of Tax Collection Article 106
Several provisions in the Minister of Finance Regulation Number 145/PMK.03/2012 concerning Procedures for the Issuance of Notice of Tax Assessment and Notice of Tax Collection (Official Gazette of the Republic of Indonesia of 2012 Number 902) as amended by the Minister of Finance Regulation Number 183/PMK.03/2015 concerning the Amendment to Minister of Finance Regulation Number 145/PMK.03/2012 concerning Procedures for the Issuance of Notice of Tax Assessment and Notice of Tax Collection (Official Gazette of the Republic of Indonesia of 2015 Number 1467), are amended as follows:

1.	The provisions of number 1 and number 2 Article 1 are amended, thereby, Article 1 reads as follows:

	Article 1
	Referred to herein this Ministerial Regulation:
	1.	General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	2.	Value Added Law, hereinafter referred to as the VAT Law, is Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	3.	Notice of Tax Underpayment Assessment is a notice of tax assessment that specifies the principal amount of tax payable, the amount of tax credit, the principal amount of tax underpayment, the amount of administrative penalties and total outstanding tax.
	4.	Notice of Additional Tax Underpayment Assessment is a notice of tax assessment that specifies an additional amount of tax payable over the previously issued tax assessment.
	5.	Notice of Nil Tax Assessment is a notice of tax assessment that specifies the principal amount of tax payable is equal to the amount of tax credit or there is no tax payable and no tax credit.
	6.	Notice of Tax Overpayment Assessment is a notice of tax assessment that specifies the amount of tax overpayment resulting from a greater amount of tax credit than tax payable or the tax that should not otherwise be payable.
	7.	Audit is a series of activities to collect and process data, information and/or evidence conducted in an objective and professional manner based on auditing standards to assess tax compliance in fulfilling tax obligations and/or for other purposes to implement statutory tax provisions.
	8.	Re-Audit is an Audit conducted on a Taxpayer for whom a notice of tax assessment has been issued based on prior Audit findings for the same type of tax and Taxable Period, a Fraction of a Tax Year or Tax Year.
	9.	Preliminary Audit is an Audit conducted to find Preliminary Evidence of whether an alleged Tax Crime has occurred.

2.	The provisions of paragraph (2) and paragraph (3) of Article 2 are deleted, paragraph (4), paragraph (5), paragraph (6) and paragraph (9) of Article 2 are amended and between paragraph (8) and paragraph (9), 1 (one) paragraph is inserted, namely paragraph (8a), thereby, Article 2 reads as follows

	Article 2
	(1)	Within a period of 5 (five) years after the tax becomes payable or the end of a Taxable Period, a Fraction of a Tax Year, or Tax Year the Director General of Taxes may issue:
		a.	the Notice of Tax Underpayment Assessment; or
		b.	the Notice of Additional Tax Underpayment Assessment.
	(2)	Deleted.
	(3)	Deleted.
	(4)	Notice of Tax Underpayment Assessment is issued in the event that there is tax that is not or underpaid based on:
		a.	Audit Findings of:
			1.	tax payable that is not or underpaid;
			2.	the Tax Return is not filed within the period referred to in Article 3 paragraph (3) of the General Provisions and Tax Procedures Law and after being reprimanded in writing, it is not submitted on time as specified in the Reprimand Letter;
			3.	Value Added Tax and Sales Tax on Luxury Goods that, in fact, should not be set off against the tax difference or should not be subject to a 0% (zero per cent) rate;
			4.	the obligations referred to in Article 28 of the General Provisions and Tax Procedures Law or Article 29 of the General Provisions and Tax Procedures Law are not fulfilled, thereby, the amount of tax liability cannot be determined;
			5.	for the Taxpayer, a Taxpayer Identification Number is issued and/or registered as a Taxable Person ex officio as referred to in Article 2 paragraph (4a) of the General Provisions and Tax Procedures Law; or
			6.	Taxable Persons do not perform supplies of Taxable Goods and/or Taxable Services and/or exports of Taxable Goods and/or Taxable Services and have been granted Input VAT refund or have credited Input VAT as referred to in Article 9 paragraph (6e) of the VAT Law; or
		b.	deleted.
	(5)	Notice of Additional Tax Underpayment Assessment is issued based on Re-Audit findings pursuant to statutory provisions in the field of taxation.
	(6)	Re-Audit referred to in paragraph (5) is conducted because of:
		a.	voluntary written statement from the Taxpayers as referred to in Article 15 paragraph (3) of the General Provisions and Tax Procedures Law;
		b.	deleted;
		c.	new data that results in an increase in the amount of tax payable, including data previously undisclosed as referred to in Article 15 paragraph (1) of the General Provisions and Tax Procedures Law; or
		d.	deleted.
	(7)	The Director General of Taxes issues a Notice of Nil Tax Assessment as referred to in Article 17A paragraph (1) of the General Provisions and Tax Procedures Law based on the Audit findings of the Tax Return if the amount of the tax credit or the amount of tax paid is equal to the amount of tax payable or no tax is due and there are neither tax credits nor tax payments.
	(8)	The Director General of Taxes issues a Notice of Tax Overpayment Assessment if based on:
		a.	examination results of the correctness of tax payments for the application for tax refunds that should not otherwise be payable as referred to in Article 17 paragraph (2) of the General Provisions and Tax Procedures Law there are tax payments that should not otherwise be payable; or
		b.	Audit findings of:
			1.	the Tax Return contains a tax credit or the amount of tax paid is greater than the amount of tax payable as referred to in Article 17 paragraph (1) of the General Provisions and Tax Procedures Law; or
			2.	the application for tax refunds as referred to in Article 17B of the General Provisions and Tax Procedures Law states that the amount of the tax credit or the amount of tax paid is greater than the amount of tax payable.
	(8a)	Included in the tax overpayment referred to in paragraph (8) subparagraph b number 2, Notice of Tax Overpayment Assessment may be issued, in the event that based on the findings of a continued audit because:
		a.	the Preliminary Audit is not followed up with an investigation as a result of the untruth of the Taxpayer’s actions as referred to in Article 8 paragraph (3) of the General Provisions and Tax Procedures Law which is in accordance with the actual situation, there remains tax overpayment; or
		b.	the investigation is terminated because the request for termination of the investigation of the Taxpayer as referred to in Article 44B of the General Provisions and Tax Procedures Law is received by the Attorney General, there remains tax overpayment.
	(9)	Notice of Tax Overpayment Assessment referred to in paragraph (8) or paragraph (8a) may continue to be issued if there is new data, including data previously undisclosed, if the overpaid tax is, in fact, greater than the assessed tax overpayment.

3.	The provisions of paragraph (4) and paragraph (5) of Article 3 are amended, thereby, Article 3 reads as follows:

	Article 3
	(1)	The notice of tax assessment referred to in Article 2 is issued for a Taxable Period, a Fraction of a Tax Year or a Tax Year.
	(2)	The notice of tax assessment for a Fraction of a Tax Year or Tax Year referred to in paragraph (1) is issued according to the Annual Income Tax Return.
	(3)	The notice of tax assessment for a Taxable Period referred to in paragraph (1) is issued according to the Taxable Period covered by the Income Tax or Value Added Tax Return.
	(4)	Excluded from the provisions referred to in paragraph (3), for the notice of tax assessment on Article 21 Income Tax, 1 (one) notice of tax assessment is issued for all Taxable Periods in 1 (one) calendar year.
	(5)	The notice of tax assessment referred to in paragraph (1) is issued according to the Taxable Period, a Fraction of a Tax Year or the Tax Year the examination, Audit or Re-Audit is conducted.

4.	The provisions of paragraph (2) of Article 4 are amended, thereby, Article 4 reads as follows:

	Article 4
	(1)	The notice of tax assessment referred to in Article 2 must be issued based on the tax calculation memo.
	(2)	The tax calculation memo referred to in paragraph (1) is prepared based on the examination results report, Audit finding report or Re-Audit finding report.

5.	Between Article 4 and Article 5, 1 (one) article is inserted, namely Article 4A, thereby, it reads as follows:

	Article 4A
	(1)	The Director General of Taxes may issue a notice of tax assessment in the electronic format and sign it electronically or issue a notice of tax assessment in the written format and sign it normally, all of which have the same legal force.
	(2)	In the event that a notice of tax assessment is prepared in the electronic format, a notice of tax assessment in the written format is not prepared.

6.	The provisions of paragraph (2) of Article 5 are amended, thereby, Article 5 reads as follows:

	Article 5
	(1)	The notice of tax assessment referred to in Article 2 must be delivered to the Taxpayer.
	(2)	The notice of tax assessment referred to in paragraph (1), may be delivered:
		a.	in person;
		b.	by post with proof of postage;
		c.	through a shipping company or courier services with proof of postage; or
		d.	electronically if the notice of tax assessment is issued electronically.

7.	Article 6 is deleted

8.	The provisions of Article 7 are amended, thereby, it reads as follows:

	Article 7
	The Director General of Taxes may issue a Notice of Tax Collection for a Taxable Period, a Fraction of a Tax Year or a Tax Year in the event that:
	a.	Income Tax in the current year is not or underpaid;
	b.	based on examination results, there is a tax underpayment due to a misspelling and/or miscalculation;
	c.	the Taxpayer is subject to administrative penalties in the form of a fine and/or interest;
	d.	the entrepreneur that has been registered as a Taxable Person , but does not prepare Tax Invoices or is late in preparing the Tax Invoices;
	e.	the entrepreneur that has been registered as a Taxable Person do not fill out the Tax Invoices completely as referred to in Article 13 paragraph (5) and paragraph (6) of the VAT Law, other than the identity of the buyer of Taxable Goods or the Taxable Service recipient as well as the name and signature as referred to in Article 13 paragraph (5) subparagraph b and subparagraph g of the VAT Law in the event that the supply is performed by a retailer Taxable Person ;
	f.	deleted;
	g.	deleted; or
	h.	there is interest compensation that should not otherwise be granted to the Taxpayer, if:
		1.	a decision is issued;
		2.	a decision is received; or
		3.	data or information is found,
		indicating the existence of interest compensation that should not otherwise be granted to the Taxpayer.

9.	The provisions of Article 8 are amended, thereby, it reads as follows:

	Article 8
	Director General of Taxes may issue the Notice of Tax Collection referred to in Article 7 after:
	a.	examining the tax administration data;
	b.	conducting an Audit; or
	c.	conducting a Re-Audit.

10.	Article 9 is deleted.

11.	Article 10 is deleted.

12.	Article 11 is deleted.

13.	Article 12 is deleted.

14.	Between Article 12 and Article 13 1 (one) article is inserted, namely Article 12A, thereby, it reads as follows:

	Article 12A
	(1)	Notice of Tax Collection is issued no later than 5 (five) years after the tax becomes payable or the end of the Taxable Period, a Fraction of a Tax Year or a Tax Year.
	(2)	Notice of Tax Collection for Article 25 Income Tax referred to in Article 14 paragraph (1) subparagraph a of the General Provisions and Tax Procedures Law, issued for unpaid or underpaid Income Tax in the current year as well as the administrative penalties on Taxpayers that have not filed the Annual Income Tax Return for the Tax Year concerned.
	(3)	Excluded from the provisions on issuance period referred to in paragraph (1):
	a.	Notice of Tax Collection for the administrative penalties referred to in Article 19 paragraph (1) of the General Provisions and Tax Procedures Law is issued no later than according to the expiration date of collection of Notice of Tax Underpayment Assessment and Notice of Additional Tax Underpayment Assessment and Amendment Decision Letter, Objection Decision Letter, Appeal Decision and Civil Review Decision, resulting in an increase in the amount of tax payable;
	b.	Notice of Tax Collection for the administrative penalties referred to in Article 25 paragraph (9) of the General Provisions and Tax Procedures Law may be issued no later than 5 (five) years from the issuance date of the Objection Decision Letter, if the Taxpayer does not file an appeal; and
	c.	Notice of Tax Collection for the administrative penalties referred to in Article 27 paragraph (5d) of the General Provisions and Tax Procedures Law may be issued no later than 5 (five) years from the date the Appeal Decision is pronounced by a Tax Court judge in a public trial.

15.	The provisions of paragraph (3) are amended, paragraph (5) of Article 13 is deleted, thereby, Article 13 reads as follows:

	Article 13
	(1)	The Director General of Taxes may issue a notice of tax assessment and/or Notice of Tax Collection for a Taxable Period, a Fraction of a Tax Year or a Tax Year before the Taxpayer is granted or issued a TIN and/or registered as a Taxable Person , if data and/or information is obtained indicating the existence of tax obligations that have not been fulfilled by the Taxpayer.
	(2)	The Director General of Taxes may issue a notice of tax assessment and/or Notice of Tax Collection for a Taxable Period, a Fraction of a Tax Year or a Tax Year before and/or after the deregistration of the TIN or the deregistration of a Taxable Person , if after the deregistration of the TIN or the deregistration of the Taxable Person , data and/or information is obtained indicating the existence of tax obligations that have not been fulfilled by the Taxpayer.
	(3)	The notice of tax assessment and/or Notice of Tax Collection referred to in paragraph (1) and/or paragraph (2) shall be issued within 5 (five) years after the time the tax becomes payable or the end of the Taxable Period, a Fraction of a Tax Year or a Tax Year as referred to in Article 2 and Article 12A.
	(4)	The notice of tax assessment and/or Notice of Tax Collection referred to in paragraph (2) shall be issued by prior reactivation of the deregistered TIN.
	(5)	Deleted.
	16.	Between Article 14 and Article 15, 1 (one) article is inserted, namely Article 14A, thereby, it reads as follows:

	Article 14A
	(1)	The Director General of Taxes may issue a Notice of Tax Collection in the electronic format and sign it electronically or in the written format and sign it normally, all of which have the same legal force.
	(2)	In the event that the Notice of Tax Collection is prepared in the electronic format, the Notice of Tax Collection is not prepared in the written format.
	(3)	Notice of Tax Collection must be delivered to the Taxpayer.
	(4)	Notice of Tax Collection referred to in paragraph (3) may be delivered:
		a.	in person;
		b.	by post with proof of postage;
		c.	through a shipping company or courier services with proof of postage; or
		d.	electronically if the Notice of Tax Collection is issued electronically.

Section Six Procedures for Preliminary Audits of Tax Crimes Article 107
Several provisions under the Minister of Finance Regulation Number 239/PMK.03/2014 concerning Procedures for Preliminary Audits of Tax Crimes (Official Gazette of the Republic of Indonesia of 2014 Number 1951), are amended as follows:

1.	The provisions of number 1 and number 3 Article 1 are amended, number 7 Article 1 is deleted and number 24 is added, thereby, Article 1 reads as follows:

	Article 1
	Referred to herein this Ministerial Regulation:
	1.	General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	2.	Land and Building Tax Law, hereinafter referred to as the PBB Law, is Law Number 12 of 1985 concerning Land and Building Tax as amended by Law Number 12 of 1994.
	3.	Stamp Duty Law is Law Number 10 of 2020 concerning Stamp Duty.
	4.	Tax Collection Using Distress Warrant Law, hereinafter referred to as PPSP Law, is Law Number 19 of 1997 concerning Tax Collection Using Distress Warrant as amended by Law Number 19 of 2000.
	5.	Tax Crime is an act that is subject to criminal penalties by the laws in the field of taxation which includes Article 38, Article 39, Article 39A, Article 41, Article 41A, Article 41B, Article 41C and Article 43 of the General Provisions and Tax Procedures Law, Article 24 and Article 25 of the Land and Building Tax Law, Article 13 and Article 14 of the Stamp Duty Law and Article 41A of the Tax Collection Using Distress Warrant Law.
	6.	Audit is a series of activities to collect and process data, information and/or evidence conducted in an objective and professional manner based on auditing standards to assess tax compliance in fulfilling tax obligations and/or for other purposes to implement statutory tax provisions.
	7.	Deleted.
	8.	Preliminary Evidence is a condition, conduct and/or evidence in the form of information, writings or objects that may strongly indicate a Tax Crime is occurring or has occurred and been committed by anyone which may cause losses to state revenues.
	9.	Preliminary Audit is Audit conducted to find Preliminary Evidence of whether an alleged Tax Crime has occurred.
	10.	Tax Crime Investigation, hereinafter referred to as Investigation, is a series of activities conducted by an investigator to find and collect evidence to uncover a Tax Crime and find the suspect.
	11.	Information is the information submitted orally or in writing that may be developed and analysed to determine whether there is Preliminary Evidence or not.
	12.	Data is a collection of numbers, letters, words or images in the form of letters, documents, books of account or records, either in the electronic or non-electronic format, which may be developed and analysed to determine whether there is Preliminary Evidence or not.
	13.	Report is the notification submitted by a person or institution due to rights and/or obligations pursuant to the law to the competent authority concerning an alleged occurrence or occurrence of a Tax Crime.
	14.	Complaint is a notification attached with a request by an interested party to the competent authority to take legal measures against an individual or entity that has committed a Tax Crime that harms the party.
	15.	Criminal Event is an event that contains a Tax Crime.
	16.	Evidence is books of accounts, records, documents, information, electronically managed data and/or other objects, which may be used to find Preliminary Evidence.
	17.	Implementation Unit of Preliminary Audits is a unit authorised to conduct Preliminary Audits pursuant to statutory provisions.
	18.	Preliminary Audit Order is a warrant issued by the head of the Implementation Unit of Preliminary Audit to conduct Preliminary Audits.
	19.	Revised Preliminary Audit Order is a Preliminary Audits Warrant issued due to a change in the Preliminary Auditor team and/or substitute of the Implementation Unit of Preliminary Audit.
	20.	Sealing is the act of placing a seal in a certain premises or room as well as movable and/or immovable property which are used or reasonably suspected to be used as a place or tool to store books of accounts or records, documents, including electronically managed data and other objects.
	21.	Preliminary Audit Working Paper is the documentation prepared by Preliminary auditors concerning the undertaken Preliminary Audit procedures, the collected Evidence, the conducted Tax Crime and the conclusions drawn in respect of the Preliminary Audit implementation.
	22.	Preliminary Audit Report is a report prepared by the Preliminary auditors that discloses the implementation, conclusions and recommendations for follow-up of Preliminary Audits.
	23.	Event Report is a written report on the existence of a Criminal Event which contains sufficient Preliminary Evidence as a basis for conducting an Investigation.
	24.	Tax Payment Slip is a receipt of tax payment or remittance using a specific form or other means to the state treasury, through a place of payment appointed by the Minister of Finance.

2.	The provisions of Article 2 are amended by adding 2 (two) paragraphs, namely paragraph (5) and paragraph (6), thereby, Article 2 reads as follows:

	Article 2
	(1)	The Director General of Taxes is authorised to conduct Preliminary Audits based on Information, Data, Reports and Complaints.
	(2)	Information, Data, Reports and Complaints referred to in paragraph (1) received or obtained by the Director General of Taxes, are developed and analysed through intelligence activities or observations.
	(3)	Information, Data, Reports and Complaints with strong indications of a Tax Crime found from the results of the development of Preliminary Audits or Investigations may be immediately followed up with a Preliminary Audit.
	(4)	Information, Data, Reports and Complaints referred to in paragraph (2) and paragraph (3) in respect of a Taxable Period, a Fraction of a Tax Year or a Tax Year, whether or not a notice of tax assessment has been issued, is followed up with a Preliminary Audits insofar as there are indications of a Tax Crime.
	(5)	Preliminary Audits conducted after the issuance of the notice of tax assessment referred to in paragraph (4) shall only be conducted on new data other than those contained in the notice of tax assessment.
	(6)	Preliminary Audits referred to in paragraph (1) may be carried out even though the period of 5 (five) years has elapsed since the end of a Taxable Period, a Fraction of a Tax Year or a Tax Year, insofar as the statute of limitation of the Tax Crime prosecution has not elapsed.

3.	The provisions of paragraph (4) and paragraph (5) of Article 5 are amended, thereby, Article 5 reads as follows:

	Article 5
	(1)	Preliminary auditors conduct a public Preliminary Audit within a maximum period of 12 (twelve) months from the date of submission of the notification of the Preliminary Audit until the date of the Preliminary Audit Report.
	(2)	Preliminary auditors conduct a restricted Preliminary Audit within a maximum period of 12 (twelve) months from the date the Preliminary Audit Order is received by the Preliminary auditors until the date of the Preliminary Audit Report.
	(3)	If the Preliminary auditors are unable to conduct Preliminary Audits within the period referred to in paragraph (1) or paragraph (2), the Preliminary auditors may apply for an extension of the period to the head of the Implementation Unit of Preliminary Audit.
	(4)	The Head of the Implementation Unit of Preliminary Audit may grant an extension of the period referred to in paragraph (3) for a maximum of 12 (twelve) months from the expiration of the period referred to in paragraph (1) or paragraph (2).
	(5)	The Head of the Implementation Unit of Preliminary Audit considers the application for an extension of the period referred to in paragraph (3) by taking into account:
		a.	deleted;
		b.	statute of limitation for the Tax Crime prosecution; or
		c.	progress of the completion of the Preliminary Audits.

4.	The provisions of paragraph (1) and paragraph (4) of Article 15 are amended, thereby, Article 15 reads as follows:

	Article 15
	(1)	Preliminary Auditors must submit the notice of the Preliminary Audit in person to the individual or entity subject to the Preliminary Audit in the event that the Preliminary Audit is conducted publicly.
	(2)	In the event that a public Preliminary Audit is conducted against an individual, the Preliminary auditors submit a notice of the Preliminary Audit to the individual subject to the Preliminary Audit, an adult family member or attorney.
	(3)	In the event that a public Preliminary Audit is conducted against an entity, the Preliminary auditors submit a notice of the Preliminary Audit to the representative, attorney or employee of the entity subject to the Preliminary Audit.
	(4)	In the event that the submission of the notice referred to in paragraph (2) and paragraph (3) cannot be carried out, the Preliminary auditors submits the notice of the Preliminary Audit:
		a.	by post with proof of postage;
		b.	by facsimile;
		c.	through a shipping company or courier services with proof of postage; or
		d.	electronically.

5.	The provisions of paragraph (1), paragraph (4) and paragraph (5) Article 23 are amended, paragraph (3) is deleted and between paragraph (5) and paragraph (6), 1 (one) paragraph is inserted, namely paragraph (5a), thereby, Article 23 reads as follows:

	Article 23
	(1)	Individuals or entities as Taxpayers subject to a public Preliminary Audit may voluntarily disclose the untruth of their actions for a crime of:
		a.	not filing a Tax Return, thereby, thereby resulting in losses to state revenues; or
		b.	filing a Tax Return whose contents are incorrect or incomplete or attach information whose contents are incorrect, thereby, resulting in losses to state revenues, as referred to in Article 38 or Article 39 paragraph (1) subparagraph c and subparagraph d of the General Provisions and Tax Procedures Law.
	(2)	Tax Return referred to in paragraph (1) is a form used by a Taxpayer to file the calculation and/or payment of taxes, taxable objects and/or non-taxable objects and/or assets and liabilities pursuant to statutory tax provisions, including:
		a.	the Annual Tax Return referred to in the General Provisions and Tax Procedures Law;
		b.	the Periodic Returns referred to in the General Provisions and Tax Procedures Law; and
		c.	the Notice of Taxable Objects referred to in the Land and Building Tax Law.
	(3)	Deleted.
	(4)	Individuals or entities as Taxpayers subject to a public Preliminary Audit may submit the untruth of actions for the crime referred to in paragraph (1) insofar as the notice of the commencement of the Investigation has not been submitted to the public prosecutor through official investigators of the Indonesian National Police.
	(5)	In carrying out the untruth of actions for a crime referred to in paragraph (1), individuals or entities as Taxpayers subject to a public Preliminary Audit must:
		a.	submit the untruth of its actions in writing and signed; and
		b.	attached with:
			1.	the calculation of the underpayment of the actual amount of tax payable;
			2.	the Tax Payment Slip or other equivalent administrative means as proof of settlement of the underpayment of the actual amount of tax payable; and
			3.	the Tax Payment Slip or other equivalent administrative means as proof of settlement of administrative penalties in the form of fines as stipulated under Article 8 paragraph (3a) of the General Provisions and Tax Procedures Law.
	(5a)	Payment of the actual amount of tax payable referred to in paragraph (5) subparagraph b number 2 and payment of administrative penalties in the form of fines referred to in paragraph (5) subparagraph b number 3 constitutes recovery of losses to state revenues.
	(6)	Individuals or entities as Taxpayers subject to a Preliminary Audit submit the untruth of actions to the head of the Tax Office where the Taxpayers are registered or where Taxable Objects are administered and the copy to the head of the Implementation Unit of Preliminary Audit.

6.	The provisions of paragraph (1) and paragraph (3) of Article 25 are amended and paragraph (2), paragraph (4) and paragraph (5) of Article 25 are deleted, thereby, Article 25 reads as follows:

	Article 25
	(1)	In the event that the Preliminary Audit is followed up with an Investigation, payment for the untruth of actions that do not fulfil the provisions referred to in Article 23 paragraph (4), paragraph (5) and paragraph (6) and/or is not in accordance with the actual situation, is taken into account as a deduction from losses to state revenues at the Investigation stage.
	(2)	Deleted.
	(3)	Payments for the untruth of actions referred to in paragraph (1) are not transferable or refundable by the Taxpayers.
	(4)	Deleted.
	(5)	Deleted.

7.	The provisions of Article 28 are amended, thereby, it reads as follows:

	Article 28
	In the event that an individual or entity as a Taxpayer being Audited to assess compliance with the fulfillment of tax obligations:
	a.	is subject to a public Preliminary Audit; or
	b.	is subject to a restricted Preliminary Audit which is followed up with an Investigation,
	the Audit shall be suspended.

8.	The provisions of paragraph (1) Article 30 are amended, thereby, Article 30 reads as follows:

	Article 30
	(1)	The results of the Preliminary Audits outlined in the Preliminary Audit Report referred to in Article 29 are followed up with:
		a.	an Investigation in the event that sufficient Preliminary Evidence is found;
		b.	a written notification by the head of the Implementation Unit of Preliminary Audit to an individual or entity as a Taxpayer subject to the public Preliminary Audit that the investigation is not carried out in the event that the untruth of the actions of an individual or entity as a Taxpayer is in accordance with the actual situation;
		c.	deleted;
		d.	termination of Preliminary Audits by the head of the Implementation Unit of Preliminary Audit in the event that an individual Taxpayer under the Preliminary Audits passes away; or
		e.	termination of Preliminary Audits by the head of the Implementation Unit of Preliminary Audit in the event that no Preliminary Evidence of a Tax Crime is found.
	(2)	In the event that the Preliminary Audit is conducted publicly, the termination of the Preliminary Audits referred to in paragraph (1) subparagraph d and subparagraph e is notified in writing by the head of the Implementation Unit of Preliminary Audit to an individual or entity or xy.

Section Seven The Application for the Termination of Tax Crime Investigations for Tax Revenue Purposes Article 108
Several provisions in the Minister of Finance Regulation Number 55/PMK.03/2016 concerning the Application for the Termination of Tax Crime Investigations for Tax Revenue Purposes (Official Gazette of the Republic of Indonesia of 2016 Number 538) are amended as follows:

1.	The provisions of number 1 of Article 1 are amended, thereby, Article 1 reads as follows:

	Article 1
	Referred to herein this Ministerial Regulation:
	1.	General Provisions and Tax Procedures Law, hereinafter referred to as the KUP Law, is Law Number 6 of 1983 concerning General Provisions and Tax Procedures as amended several times, last amended by Law Number 11 of 2020 concerning Job Creation.
	2.	Tax crime Investigation, hereinafter referred to as Investigation, is a series of activities conducted by an investigator to find and collect evidence to uncover tax crime and find the suspect.

2.	The provisions of paragraph (1) of Article 3 are amended, thereby, Article 3 reads as follows:

	Article 3
	(1)	The Taxpayer’s applications referred to in Article 2 paragraph (2) may be submitted after the Taxpayer has paid the tax that is not or underpaid or which should not otherwise be refunded and is added with administrative penalties in the form of a fine of 3 (three) times the amount of tax not or underpaid or that should not otherwise be refunded.
	(2)	Included in taxes paid by the Taxpayer referred to in paragraph (1) are taxes that are not or underpaid or that should not otherwise be refunded as a result of:
		a.	issuance and/or use of Tax Invoices, collection receipt, withholding receipt and/or receipt of tax remittance, which are not based on actual transactions; and/or
		b.	issuance of Tax Invoices before the Entrepreneur is registered as a Taxable Person .

3.	Between Article 11 and Article 12, 1 (one) article is inserted, namely Article 11A, thereby, it reads as follows:

	Article 11A
	(1)	Documents related to the termination of an Investigation may be prepared electronically and signed electronically or prepared in writing and signed normally, all of which have the same legal force.
	(2)	Documents referred to in paragraph (1) may be submitted:
		a.	in person;
		b.	by post or shipping services with proof of postage; or
		c.	electronically.

4.	The attachment referred to in Article 11 is amended as listed in Appendix XXVII which constitutes an integral part of this Ministerial Regulation.

CHAPTER V TRANSITIONAL PROVISIONS Article 109
(1)	For domestically-sourced Dividends received or accrued by a Taxpayer since the entry into force of Law Number 11 of 2020 concerning Job Creation, that are excluded from Income Tax objects as referred to in Article 15 for which Withholding Tax has been carried out, an application for tax refunds which should not otherwise be payable may be submitted.
(2)	Application for tax refunds that should not otherwise be payable referred to in paragraph (1) is carried out pursuant to the Minister of Finance Regulation concerning procedures for tax refunds that should not otherwise be payable.


Article 110
(1)	The certain period for Taxable Persons that Have Not Performed Any Supply and have performed Input VAT crediting for acquisitions of capital goods before 2 November 2020, is stipulated pursuant to the provisions under this Ministerial Regulation.
(2)	In the event that Taxable Persons that Have Not Performed Any Supply amend the Periodic VAT Return in a Taxable Period before 2 November 2020 which causes the Periodic VAT Return to be overpaid, the provisions on the refunds of Input VAT overpayment shall be pursuant to the provisions under this Ministerial Regulation.
(3)	Taxable Persons may apply for a relief in the amount of tax stated in the notice of tax assessment as stipulated under Article 36 paragraph (1) subparagraph b of the General Provisions and Tax Procedures Law for notices of tax assessment issued on 2 November 2020 until the entry into force of this Ministerial Regulation on supplies of Taxable Goods and/or Taxable Services before an Entrepreneur is registered as a Taxable Person provided that:
	a.	audit findings do not take into account Input VAT using the Input VAT crediting guidelines referred to in Article 65; and
	b.	the Taxable Persons disapprove of the audit findings referred to in subparagraph a.
(4)	Input VAT on acquisitions of Taxable Goods and/or Taxable Services, imports of Taxable Goods and utilisation of intangible Taxable Goods and/or utilisation of Taxable Services from outside the Customs Territory within the Customs Territory collected with a tax assessment as referred to in Article 68 issued before 2 November 2020 may be credited by the Taxable Persons insofar as the provisions referred to in Article 68 paragraph (1) are fulfilled and the amount of outstanding VAT includes the tax principal and penalties stated in the tax assessment has been paid as of 2 November 2020.

Article 111
The granting of interest compensation and the application for the granting of interest compensation that has not been completed until this Ministerial Regulation comes into force, which is based on an assessment, decision or verdict, which is issued or pronounced:
a.	before 2 November 2020, shall be completed pursuant to the provisions under the Minister of Finance Regulation Number 226/PMK.03/2013 concerning Procedures for the Calculation and Granting of Interest Compensation as amended several times, last amended by the Minister of Finance Regulation Number 65/PMK.03/2018; or
b.	after 2 November 2020, shall be completed pursuant to the provisions under this Ministerial Regulation,
and the completion period for the granting of interest compensation is no later than 1 (one) month from the date the application submitted since this Ministerial Regulation comes into force, is completely received by the Tax Office.

Article 112
Applications for instalments or deferral of tax payments that have not been completed until this Ministerial Regulation comes into force, shall be settled pursuant to the provisions stipulated in the Minister of Finance Regulation Number 242/PMK.03/2014 concerning Procedures for the Payment and Remittance of Taxes.

Article 113
(1)	For Input VAT that has been refunded or has been credited by Taxable Persons that do not perform supplies of Taxable Goods, supplies of Taxable Services, exports of Taxable Goods and/or exports of Taxable Services that should be refunded as referred to in Article 9 paragraph (6e) of the VAT Law:
	a.	that has passed the refund deadline referred to in Article 9 paragraph (6f) of the VAT Law; and
	b.	payment has not been made until 2 November 2020,
	a Notice of Tax Underpayment Assessment referred to in Article 13 paragraph (1) subparagraph f of the General Provisions and Tax Procedures Law shall be issued.
(2)	Interest compensation that should not otherwise be granted and no refund has been carried out by the Taxpayer until 2 November 2020 shall be collected by issuing a Notice of Tax Collection as referred to in Article 14 paragraph (1) subparagraph h of the General Provisions and Tax Procedures Law.

Article 114
Preliminary Audits that have received approval for the extension of the Preliminary Audit period before this Ministerial Regulation comes into force, shall be completed according to the period specified in the approval of the extension pursuant to the provisions stipulated in the Minister of Finance Regulation Number 239/PMK.03/2014 concerning Procedures for Preliminary Audits of Tax Crimes.

Article 115
Applications for the termination of tax crime Investigations which have not been completed until this Ministerial Regulation comes into force, shall be completed pursuant to the provisions stipulated in the Minister of Finance Regulation Number 55/PMK.03/2016 concerning Applications for the Termination of Tax Crime Investigations for Tax Revenue Purposes.

Article 116
(1)	The imposition of administrative penalties on:
	a.	the notice of tax assessment or Notice of Tax Collection issued after 2 November 2020 containing administrative penalties in the form of interest, in which the calculation of administrative penalties commences before 2 November 2020; or
	b.	the disclosure of incorrect Tax Return completion filed after 2 November 2020,
	is calculated using the interest rate pursuant to the Minister of Finance Decree stipulating the interest rate as the basis for calculating administrative penalties in the form of interest and the provision of interest compensation applicable for November 2020;
(2)	For the submission of:
	a.	the untruth of actions referred to in Article 8 paragraph (3) of the General Provisions and Tax Procedures Law; and
	b.	requests for the termination of investigations as referred to in Article 44B of the General Provisions and Tax Procedures Law,
	by Taxpayers since 2 November 2020, the administrative penalties are imposed pursuant to the General Provisions and Tax Procedures Law; and
(3)	Administrative penalties referred to in Article 14 paragraph (4) of the General Provisions and Tax Procedures Law through the Notice of Tax Collection issued after 2 November 2020 are imposed pursuant to the General Provisions and Tax Procedures Law.

CHAPTER VI CLOSING PROVISIONS Article 117
When this Ministerial Regulation comes into force:
a.	Minister of Finance Regulation Number 111/PMK.03/2010 concerning Procedures for the Withholding, Remittance and Filing of Income Tax on Dividends Received or Accrued by Resident Individual Taxpayers (Official Gazette of the Republic of Indonesia of 2010 Number 278);
b.	Minister of Finance Regulation Number 107/PMK.03/2017 concerning the Determination of the Time Dividends Are Accrued and its Calculation Basis by Resident Taxpayers for Capital Participation in Business Entities Overseas Other than Listed Business Entities (Official Gazette of the Republic of Indonesia of 2017 Number 1043) as amended by the Minister of Finance Regulation Number 93/PMK.03/2019 concerning the Amendment to the Minister of Finance Regulation Number 107/PMK.03/2017 concerning the Determination of the Time Dividends Are Accrued and its Calculation Basis by Resident Taxpayers for Capital Participation in Business Entities Overseas Other than Listed Business Entities (Official Gazette of the Republic of Indonesia of 2019 Number 702); and
c.	Minister of Finance Regulation Number 192/PMK.03/2018 concerning the Implementation of Tax Crediting for Foreign-Sourced Income (Official Gazette of the Republic of Indonesia of 2018 Number 1837),
remain valid insofar as they do not contradict the provisions under this Ministerial Regulation.

Article 118
When this Ministerial Regulation comes into force:
a.	Minister of Finance Regulation Number 151/PMK.03/2013 concerning Procedures for the Preparation or Replacement of Tax Invoices (Official Gazette of the Republic of Indonesia of 2013 Number 1313);
b.	Minister of Finance Regulation Number 226/PMK.03/2013 concerning Procedures for the Calculation and Granting of Interest Compensation (Official Gazette of the Republic of Indonesia of 2013 Number 1630) as amended several times, last amended by Minister of Finance Regulation Number 65/PMK.03/2018 concerning the Second Amendment to the Minister of Finance Regulation Number 226/PMK.03/2013 concerning Procedures for the Calculation and Granting of Interest Compensation (Official Gazette of the Republic of Indonesia of 2018 Number 820); and
c.	Minister of Finance Regulation Number 31/PMK.03/2014 concerning the Time of Calculation and Procedures for the Refund of Input VAT that Has Been Credited and Refunded for Taxable Persons Experiencing Production Failure (Official Gazette of the Republic of Indonesia of 2014 Number 199),
are revoked and declared invalid.

Article 119
This Ministerial Regulation shall come into force on the date of promulgation.

For public cognisance, this Ministerial Regulation shall be promulgated by placement in the Official Gazette of the Republic of Indonesia.

Enacted in Jakarta on 17 February 2021 MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA, signed SRI MULYANI INDRAWATI Promulgated in Jakarta on 17 February 2021 DIRECTOR GENERAL OF LEGISLATION MINISTRY OF LAW AND HUMAN RIGHTS OF THE REPUBLIC OF INDONESIA, signed WIDODO EKATJAHJANA OFFICIAL GAZETTE OF THE REPUBLIC OF INDONESIA OF 2021 NUMBER 153

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MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA REGULATION NUMBER 18/PMK.03/2021

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MINISTER OF FINANCE OF THE REPUBLIC OF INDONESIA REGULATION
NUMBER 18/PMK.03/2021