Latest Format of List of Uncollectible Receivables in Coretax Annual Tax Return

Introduction

The implementation of the Core Tax Administration System (Coretax) brings a major reform to the reporting procedures of the Annual Tax Return (SPT Tahunan), both for Corporate Taxpayers and Individuals maintaining bookkeeping. One crucial component undergoing strict standardization is the reporting of Uncollectible Receivables (Bad Debts).

Under Indonesian tax regulations, losses from bad debts can be claimed as a deductible expense from gross income only if specific cumulative requirements set by law are met. One of the most important administrative requirements is the obligation to submit a nominative list of these receivables to the Directorate General of Taxes (DGT).

In the Coretax era, this list is no longer a CSV or PDF attachment with a format created by the Taxpayer. Coretax provides a structured data format that must be filled in directly (key-in) or imported via a standardized XML schema. Failure to fill this list according to the new format may result in the bad debt expense being fiscally corrected (positive correction), leading to an increase in Income Tax (PPh) payable.

This article will detail the latest format based on Director General of Taxes Regulation Number PER-11/PJ/2025, complete with case illustrations and filling procedures.

Legal Basis and Regulatory Reference

The changes in format and reporting mechanism are based on the following regulations:

1. Income Tax Law (UU PPh): Article 6 paragraph (1) letter h, regulating the conditions for deducting bad debts.
2. Government Regulation Number 55 of 2022: Article 19, detailing formal and material requirements for bad debts, including document proof exceptions for small debtors,.
3. Minister of Finance Regulation Number 81 of 2024: Regarding Tax Provisions for the Implementation of the Core Tax Administration System.
4. Director General of Taxes Regulation Number PER-11/PJ/2025: Concerning Form, Content, and Procedures for Filing Annual Tax Returns. This specifically regulates the location and data structure of the receivables list in Coretax.

Location of Uncollectible Receivables List in Coretax

In the structure of the Coretax Annual SPT form, the List of Uncollectible Receivables is placed in a specific location depending on the Taxpayer type:

• Corporate Taxpayers: Located in Attachment 11A (Lampiran 11A) Part III.
• Individual Taxpayers (Bookkeeping): Located in Attachment 3D (Lampiran 3D) Part C,.

Table Format of Uncollectible Receivables List (Latest)

Based on the Appendix of PER-11/PJ/2025 and Coretax technical guides, the following data structure (columns) must be filled.

Table 1: Data Structure of Uncollectible Receivables List in Coretax

Important: In Coretax, the proof document requirement (Column 8) is not applicable (optional) if the written-off receivable comes from a small debtor or other small debtors as regulated by law (e.g., micro-loans, subsidized housing loans),.

Case Illustration

To provide a clearer picture, let's simulate the filling of this list using a trading company case.

Case Scenario: PT Distribusi Lancar Jaya

PT Distribusi Lancar Jaya (PT DLJ) is an electronics distributor. In the 2025 tax year, the company wrote off uncollectible receivables totaling Rp350,000,000, which were expensed in the Commercial Income Statement. The details are as follows:

1. Debtor A (Toko Maju Terus): Owes Rp200,000,000. Due to bankruptcy, the collection case has been submitted to the Central Jakarta District Court.
2. Debtor B (CV Elektronik Abadi): Owes Rp100,000,000. A written agreement was made between PT DLJ and CV Elektronik Abadi regarding the forgiveness of the remaining debt due to force majeure (shop fire).
3. Debtor C (Mr. Budi - Small Debtor): An individual debtor (small debtor) with a remaining debt of Rp50,000,000, which is an accumulation of several micro-transactions. The write-off was done without newspaper publication because it meets the small debtor criteria under the MoF Regulation.

Below is how PT DLJ fills Attachment 11A Part III in Coretax:

Table 2: Filling Illustration in Coretax (Attachment 11A Part III)

Note for Debtor C: Since this is a small debtor, the proof document type column can be left blank or adjusted to the available exception option in the application.

Validity Analysis and Impact in Coretax

The Coretax system does not just digitize forms but also performs real-time and integrated data validation.

1. Identity Validation (TIN Validation)

The Identity Number column is key. If a Taxpayer enters an invalid NPWP or one with a deleted status, the Coretax system will likely reject the entry or issue a warning. This differs from the old e-Filing system where PDF attachment validation was often not real-time. This forces Taxpayers to ensure their debtor master file data is accurate,.

2. Integration with Income Statement

The total value in the "Amount of Uncollectible Receivables" column in this attachment must reconcile with the bad debt expense account in Attachment 1 (Income Statement). If there is a discrepancy, Coretax will detect this anomaly, which may trigger a risk flag in Compliance Risk Management (CRM).

3. Proof Document Requirements

Coretax requires Taxpayers to select the proof document type. Although the physical documents might not always be uploaded one by one in the attachment menu (depending on file size), Taxpayers must keep these documents (Minutes, Court Verdicts, Newspaper Clippings). Coretax provides an "Additional Documents" menu in the Main SPT to upload these proofs if required,. Absence of these documents during an audit will result in the expense being corrected.

Filling Mechanisms: Manual vs Import

Taxpayers have two options for filling this list in Coretax:

1. Key-In (Manual Input): Users click the "Add" (+ Tambah) button on Attachment 11A Part III (Corporate) or L-3D Part C (Individual). A pop-up form appears, and users fill in data one by one according to the columns in Table 1. This option is suitable for companies with few bad debtors.
2. Data Import (XML Upload): For companies (like Banks or Multi-finance) with hundreds or thousands of bad debtors, Coretax provides an XML Upload feature.
   • Taxpayers download the Excel scheme/template provided by DGT.
   • Fill in data massively in Excel.
   • Convert to XML format using the official converter.
   • Upload the XML file to the attachment menu. Data will populate automatically into the table.

Conclusion

The latest format of the List of Uncollectible Receivables in Coretax demands a higher level of detail and accuracy. The transition from unstructured attachments (free PDF/Excel) to structured data (XML/Database) allows the DGT to perform deeper data analysis.

The key to ensuring bad debt expenses are fiscally recognized (deductible) in the Coretax era are:

1. Data Completeness: Ensure debtor NPWP/NIK is valid.
2. Compliance with Conditions: Ensure the proof document type matches what is selected in the system (e.g., if selecting "Publication", ensure the newspaper clipping exists).
3. Consistency: Ensure the figures in this list match the figures in the Financial Statements (Attachment 1).

Taxpayers are advised to update their receivables administration throughout the year so that when the Annual Tax Return reporting period arrives, data is ready to be imported into the Coretax system without issues.

References

• Peraturan Direktur Jenderal Pajak Nomor PER-11/PJ/2025 tentang Ketentuan Pelaporan Pajak Penghasilan, PPN, dan PPnBM dalam Rangka Pelaksanaan Sistem Inti Administrasi Perpajakan.
• Peraturan Menteri Keuangan Nomor 81 Tahun 2024 tentang Ketentuan Perpajakan dalam Rangka Pelaksanaan Sistem Inti Administrasi Perpajakan.
• Peraturan Pemerintah Nomor 55 Tahun 2022 tentang Penyesuaian Pengaturan di Bidang Pajak Penghasilan.
• Undang-Undang Nomor 7 Tahun 1983 tentang Pajak Penghasilan s.t.d.t.d Undang-Undang Harmonisasi Peraturan Perpajakan (HPP).