Filling Out the List of Debt and Capital in Affiliated Companies in the Corporate Annual Tax Return (Coretax)

1. Introduction

The implementation of the Core Tax Administration System (Coretax) brings significant changes to the reporting procedures of the Corporate Annual Income Tax Return (SPT Tahunan PPh Badan). One aspect receiving special attention in this new system is the transparency of transactions with related parties (affiliates).

In the global and domestic tax ecosystem, the capital and debt structure between affiliated companies is often used as an aggressive tax planning instrument, such as thin capitalization (minimizing equity to maximize debt to claim interest expenses). Therefore, the DGT through Coretax tightens supervision by standardizing affiliate data reporting forms.

In the Coretax Corporate Annual Tax Return, the reporting of debt, receivables, and capital participation balances to affiliated parties is no longer scattered or in unstructured attachments. This data is centralized in Attachment 2 (L2) Part B, which is integrated with validation logic in the Master Form and the Debt to Equity Ratio (DER) calculation in Attachment 11B. This article will discuss in depth how to fill it out, technical implications, and case illustrations according to the latest regulations.

2. Legal Basis and Regulatory References

This filling procedure is based on the following laws and regulations:

1. Director General of Taxes Regulation Number PER-11/PJ/2025: Concerning the Form, Content, and Procedure for Filling the Annual Income Tax Return for Corporate Taxpayers. This regulation governs the structure of Attachment 2 containing ownership and affiliate lists.
2. Minister of Finance Regulation Number 81 of 2024: Concerning Tax Provisions for the Implementation of the Core Tax Administration System.
3. Minister of Finance Regulation Number 169/PMK.010/2015: Concerning the Determination of the Debt to Equity Ratio for Income Tax Calculation Purposes.
4. Income Tax Law Article article 18 paragraph (4): Defining special relationships (affiliates).

3. Trigger Mechanism in Coretax

In Coretax, filling forms is dynamic. The input columns for affiliate debt/capital will not appear or be active unless the Taxpayer provides confirmation in the transaction statement section.

Activation Steps:

1. Enter the Master Annual SPT Form (Induk).
2. Navigate to Section H (Transaction Statement).
3. Answer question number 21.c: "Is there capital investment in affiliated companies?" Select YES if applicable.
4. Answer question number 21.d: "Does the Taxpayer have debt from capital owners or affiliated companies, and/or receivables to capital owners or affiliated companies?" Select YES if applicable.

If these questions are answered "YES", the system will activate Attachment 2 Part B (L2.B) for filling.

4. Structure of Attachment 2 Part B

Attachment 2 Part B is titled "List of Capital Participation, Debt, and/or Receivables in Affiliated Companies". This section must be filled with year-end balances based on commercial financial statements.

Below are the details of the columns that must be filled in the Coretax table:

Important Note: The data input is cumulative per affiliate entity. If there are affiliate transactions, this data must also be consistent with Attachment 10A (List of Related Party Transactions) and Attachment 11B (DER Calculation).

5. Relationship with Attachment 11B (DER)

Filling out Attachment 2 Part B does not stand alone. The affiliate debt data you enter here will be cross-referenced with Attachment 11B Part II.A (Calculation of Average Debt Balance).

In Attachment 11B, Taxpayers must detail monthly debt balances and select the creditor relationship status: "Affiliate" or "Independent". If in L2B you report an affiliate debt of IDR 10 Billion, logically in Attachment 11B there must also be a recorded debt with "Affiliate" status with a relevant value (after averaging). Inconsistency between L2 and L11B can trigger a risk flag in the DGT's CRM system.

6. Filling Case Illustration

To clarify the technical filling, let's use the following case study:

Case Scenario: PT Gemilang Makmur

Profile:

• Taxpayer Name: PT Gemilang Makmur (Indonesia)
• Currency: Rupiah (IDR)
• Tax Year: 2025

Affiliate Transaction Data:

1. Parent Company: PT Holdings Inti (Indonesia). PT Gemilang Makmur has a working capital loan of IDR 50,000,000,000 since 2023. Interest paid in 2025 is IDR 2,500,000,000.
2. Subsidiary: Gemilang Singapore Pte. Ltd. (Singapore). PT Gemilang Makmur has a 60% share investment valued at IDR 10,000,000,000. Additionally, PT Gemilang Makmur provided a loan (receivable) to this subsidiary of IDR 5,000,000,000 in 2024, with 2025 interest income of IDR 200,000,000.

Filling Steps in Coretax:

1. Master SPT Part H: Answer YES to questions 21.c and 21.d.
2. Open Attachment 2 (L2) and scroll to Part B.
3. Click the "Add" button to fill in data per entity.

Illustration Table: Filling Attachment 2 Part B

Note: Values in Rupiah. Number format in Coretax does not use dot/comma separators during input (e.g., 50000000000).

7. Tips and Critical Validation Points

To ensure successful reporting and avoid errors or future audits, consider the following:

• TIN/NPWP Validation: Ensure domestic affiliate NPWP is valid (16 digits). For foreign affiliates, ensure the Tax Identification Number (TIN) is filled correctly according to the counterparty's country format. Incorrect TIN can hinder Exchange of Information (EoI).
• DER Consistency: The affiliate debt balance in Attachment 2B must be considered when filling Attachment 11B. If the total debt in L2B is very large compared to equity in the Balance Sheet, ensure you have calculated the non-deductible borrowing costs in Attachment 11B according to PMK-169/2015.
• TP Doc: If the value of affiliate transactions (including debt/receivables balances and interest) exceeds the threshold regulated in PMK 172/2023, the Coretax system will trigger questions regarding the obligation to submit Transfer Pricing Documentation (TP Doc) in the Master SPT. Ensure data in L2B is consistent with what is presented in your TP Doc.
• Reasonable Interest: Ensure the reported interest rate (Interest divided by Average Balance) reflects the Arm's Length Principle. Anomalous interest rates can be automatically detected by the system.

8. Conclusion

Filling out the List of Debt and Capital in Affiliated Companies in the Coretax Corporate SPT requires a high level of accuracy and data integrity. The integration between Attachment 2 Part B, Attachment 11B (DER), and Attachment 10 (TP) creates an interlocking data ecosystem. Taxpayers are advised to prepare working papers detailing balances and interest per affiliate entity before inputting into the system to ensure data consistency across attachments.