Compliance Transformation: Certain Taxpayers Are Now Required to Submit Article 25 Income Tax Calculation Reports in Coretax

1. Introduction

In the Indonesian tax ecosystem, Article 25 Income Tax (PPh Pasal 25) is a monthly tax installment mechanism designed to ease the tax burden at the end of the year. Generally, the amount of this installment is based on the previous year's Annual Tax Return (SPT). However, for certain business sectors with dynamic and fluctuating business characteristics, the calculation basis from the previous year is often irrelevant to the actual conditions of the current year.

Therefore, Minister of Finance Regulation Number 215/PMK.03/2018 (now updated in PMK 81 of 2024 and PER-11/PJ/2025) establishes a category of Certain Taxpayers (Wajib Pajak Tertentu) who must calculate Article 25 installments based on periodic financial statements (monthly or quarterly), not based on the previous year's Annual SPT.

With the implementation of the Core Tax Administration System (Coretax), this reporting mechanism has undergone total digitalization. Whereas reporting was previously often manual or separate, Coretax integrates this obligation directly into the Corporate Annual Income Tax Return flow as a trigger and provides a standardized reporting menu. This article will discuss in depth who is included in Certain Taxpayers, how the reporting mechanism works in Coretax, and calculation illustrations.

2. Legal Basis and Regulatory References

Changes to these procedures and the affirmation of obligations are based on the following legal framework:

1. Law Number 7 of 1983 concerning Income Tax as amended by the Harmonization of Tax Regulations Law (Article 25 paragraph 6).
2. Minister of Finance Regulation Number 81 of 2024 concerning Tax Provisions for the Implementation of the Core Tax Administration System. Article 144 et seq. regulates installment calculations for Certain Taxpayers.
3. Director General of Taxes Regulation Number PER-11/PJ/2025 concerning Reporting Provisions for Income Tax, VAT, LGST, and Stamp Duty for the Implementation of the Core Tax Administration System. This regulation provides standard formats for installment calculation reports for Banks, SOEs (BUMN), Regional Owned Enterprises (BUMD), and Listed Companies.

3. Who are "Certain Taxpayers"?

In the context of Coretax and the latest regulations, Taxpayers who are required to submit Article 25 Income Tax Calculation Reports periodically and receive special treatment in the Annual SPT are:

1. Bank Taxpayers: Due to high volatility in interest income and operations.
2. State-Owned Enterprises (BUMN) and Regional-Owned Enterprises (BUMD): Especially those related to public interest and budget transparency.
3. Listed Taxpayers (Emiten): Public companies (Tbk) whose shares are traded on the stock exchange, other than Banks.
4. Other Taxpayers: Taxpayers who are required by law to prepare periodic financial statements (e.g., Financing Institutions, Pension Funds).

For the entities above, Article 25 installments are not calculated from the previous year's Annual SPT divided by 12, but are calculated based on profit and loss realization in periodic financial statements (monthly or quarterly) of the current year, annualized.

4. Reporting Mechanism in Coretax

Coretax changes the way Taxpayers report this obligation through a dynamic validation feature when filling out the Corporate Annual SPT. Here is the workflow:

A. Trigger in Master Form (Part G)

When Corporate Taxpayers fill out the Annual SPT in Coretax, they will reach Part G: Calculation of Article 25 Income Tax Installments for the Current Year.

In this section, there is a crucial question (Question Number 20): "Is the Taxpayer a certain Taxpayer required to submit the Article 25 Income Tax Installment Calculation Report?".

Taxpayers have two answer options:

1. Answer "NO" (TIDAK):
   • This applies to General Taxpayers (e.g., Trading Companies, Non-listed Manufacturers, Construction Services).
   • Consequence: The system will require filling out Attachment 6 (Installment of Income Tax for the Current Tax Year). Here, the Taxpayer calculates next year's installment based on this year's fiscal profit.
2. Answer "YES" (YA):
   • This applies to Banks, BUMN, BUMD, and Listed Companies.
   • Consequence: Attachment 6 will be disabled/locked or the Taxpayer does not need to fill out Attachment 6.
   • Substitute Obligation: Taxpayers are directed to submit the Article 25 Income Tax Installment Calculation Report according to the format stipulated in PER-11/PJ/2025 (Format Letter I) periodically (per tax period) through a separate menu in Coretax or attached as a document.

B. Calculation Report Format (According to PER-11/PJ/2025)

In Coretax, this report format has been standardized into a digital form or data import scheme, which includes:

• For Banks: Details of commercial net income, fiscal corrections, fiscal net income, loss compensation, annualized Taxable Income, and tax credits.
• For BUMN/BUMD & Listed Companies: Similar details but based on annualized quarterly or semi-annual financial statements.

5. Case Illustration and Calculation

To understand the difference in treatment in Coretax, let's compare two companies: PT Dagang Biasa (General WP) and PT Bank Maju Tbk (Certain WP).

Scenario 1: PT Dagang Biasa (General WP)

• Status: Private company, trading sector.
• 2024 SPT Data: Tax Payable IDR 120 Million. Tax Credit IDR 20 Million.
• Coretax Filling:
  • In Master Part G Question 20, answers "NO".
  • The system opens Attachment 6.
  • PPh 25 Calculation (Attachment 6): (IDR 120 Million - IDR 20 Million) / 12 months = IDR 8,333,333 per month for 2025.

Scenario 2: PT Bank Maju Tbk (Certain WP)

• Status: Publicly Listed Banking Company (Tbk).
• Obligation: Submit monthly financial statements to OJK and DGT.
• Condition: Reporting 2024 Annual Tax Return in April 2025.
• Financial Data March 2025 (Quarter I):
  • Fiscal Net Profit (Jan-Mar 2025): IDR 30 Billion.
  • Tax Credit PPh 23/24 (Jan-Mar 2025): IDR 2 Billion.

Coretax Filling & Installment Calculation:

1. In 2024 Annual SPT (Master Form):
   • In Part G Question 20, PT Bank Maju Tbk answers "YES".
   • Result: No need to fill out Attachment 6. The Article 25 installment column for the next year in the Annual SPT becomes nil or irrelevant because the installment is dynamic monthly.
2. Monthly Reporting Obligation (PPh 25 Calculation Report): PT Bank Maju Tbk is required to login to Coretax every tax period to report the installment calculation based on that month's realization.

Illustration Table of PPh 25 Calculation for Period March 2025 (Bank):

Note: The figure of IDR 1.53 Billion is what must be paid for the April 2025 Tax Period (due May 15, 2025) and reported via the PPh 25 Calculation Report menu in Coretax.

6. Integration with Taxpayer Account Management (TAM)

One of Coretax's advantages is the Taxpayer Account Management (TAM) feature. Article 25 PPh installment data reported by Certain Taxpayers will be directly recorded in the Taxpayer's Tax Ledger.

• Debit Side: When a Certain WP submits the PPh 25 Calculation Report (e.g., resulting in IDR 1.53 Billion), the system records it as a liability (Establishment/Tax Debt).
• Credit Side: When the WP makes a payment using a Billing Code, the system records it as a settlement.
• Automatic Validation: If a Certain WP does not submit this report, or the payment value is less than the calculated report, the Coretax system can automatically issue a Tax Collection Letter (STP) for the underpayment along with administrative sanctions.

7. Important Points to Note

1. Identify Status: Ensure you know whether your company falls into the Certain WP category according to PMK 81/2024. An error in answering the question in the Master Form (Part G Number 20) will cause a fatal error in determining the installment obligation for the next year.
2. Attachment 11B (Borrowing Costs): For Banks and Financial Institutions that are Certain WPs, although they do not fill out Attachment 6, they must still pay attention to filling out Attachment 11B regarding borrowing cost limitations (DER/EBITDA), even though the banking sector has specific exceptions in DER rules.
3. Timely Compliance: Periodic financial statements that form the basis of calculation must be prepared on time. Delays in preparing internal financial statements will hinder PPh 25 reporting in Coretax and potentially incur penalties for late Periodic SPT reporting.
4. Prepopulated Feature: PPh 25 installment payments made will appear as prepopulated (automatically filled) in the Annual SPT Master Form Tax Credit Section (Part E or Attachment 3) at the time of annual reporting, facilitating reconciliation.

8. Conclusion

The obligation to submit the Article 25 Income Tax Installment Calculation Report for Certain Taxpayers (Banks, SOEs, Listed Companies) in Coretax is a manifestation of modernization that prioritizes real-time data. This system strictly separates General WPs who use the previous year's basis (via Attachment 6) from Certain WPs who use the actual basis (via Periodic Reports).

The key to compliance in the Coretax era is understanding Trigger Question Number 20 in the SPT Master Form. Answering "YES" to this question exempts the WP from Attachment 6 but activates stricter periodic reporting obligations. Taxpayers are expected to prepare accounting systems capable of generating interim financial statements quickly and accurately to support compliance in Coretax.