Latest Format of Nominative List of Entertainment Expenses in Coretax Annual Tax Return

Introduction

The implementation of the Core Tax Administration System (Coretax) brings fundamental changes to tax reporting procedures in Indonesia. One crucial aspect undergoing digitalization and standardization is the reporting of Entertainment Expenses in the Annual Income Tax Return (SPT Tahunan).

According to tax regulations, entertainment, representation, and similar expenses are generally deductible from gross income for calculating Taxable Income, provided they are strictly used for business purposes (getting, maintaining, and collecting income). However, an absolute requirement for deductibility is that the Taxpayer must create a Nominative List and attach it to the Annual Tax Return.

In the Coretax era, this Nominative List is no longer a free-format attachment or a random PDF upload. Instead, it has become structured data that must be filled into a specific form or imported via a standardized XML schema. This article thoroughly explores the latest format based on the most recent regulation, Director General of Taxes Regulation Number PER-11/PJ/2025.

Legal Basis and Regulatory Reference

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

1. Income Tax Law (UU PPh): Article 6 paragraph (1) letter a, which stipulates that costs for getting, collecting, and maintaining income are deductible.
2. Circular of DGT No. SE-27/PJ.22/1986: The foundational rule requiring the nominative list.
3. Minister of Finance Regulation Number 81 of 2024: Regarding Tax Provisions for the Implementation of the Core Tax Administration System,.
4. DGT Regulation Number PER-11/PJ/2025: Concerning the Form, Content, and Procedures for Filling Annual Income Tax Returns. This regulation specifically dictates the new attachment formats in Coretax.

Paradigm Shift in Coretax

Before Coretax, Taxpayers often created Nominative Lists using their own Excel formats and converted them to PDF for e-Filing. In Coretax, the Nominative List for Entertainment Expenses has a specific "home":

• For Individual Taxpayers (Bookkeeping): Located in Attachment 3D (L-3D) Part A.
• For Corporate Taxpayers: Located in Attachment 11A Part II,.

Latest Table Format for Nominative List of Entertainment Expenses

Based on the Appendix of PER-11/PJ/2025, the following are the data columns that Taxpayers must fill in the Coretax system. This data is divided into two main groups: Provision Information and Business Relation Information.

Table 1: Data Structure of Nominative List in Coretax

Important Note: In Coretax, Taxpayers no longer need to attach additional physical/PDF documents if the data above has been keyed in or imported (via XML/Excel converter) into the electronic form, unless specifically requested during an audit,.

Case Illustration

To understand the correct filling method so that these costs are fiscally recognized (deductible), let's look at the following case illustration.

Case Scenario: PT Sukses Makmur Abadi

PT Sukses Makmur Abadi (PT SMA) is a heavy equipment distributor. In the 2025 tax year, the company recorded several entertainment-related expenses in its commercial financial statements:

1. Transaction A: On April 12, 2025, the Director treated Mr. Budi (Director of PT Konstruksi Jaya, a potential client) to dinner at "Steak House Jakarta" to discuss a contract renewal. Cost: Rp5,000,000.
2. Transaction B: On September 5, 2025, the Marketing Manager took Mr. Andi (Procurement Manager of PT Tambang Emas) golfing at "Jagorawi Golf Club" to lobby for a tender. Cost: Rp15,000,000.
3. Transaction C: On December 20, 2025, the company held an internal birthday party for all employees at a 5-star hotel. Cost: Rp50,000,000.

Tax Treatment Analysis:

• Transactions A & B: These are business-related entertainment expenses (getting/collecting income) given to business relations. Deductible provided a Nominative List is created.
• Transaction C: This is an expense for internal interests (employees). In the context of the Entertainment Nominative List (Attachment 11A Part II / L-3D Part A), this does not belong here. If considered Natura (Benefit in Kind) for employees, it goes to Attachment 11A Part I / L-3D Part B (Natura List). However, pure celebratory parties are often Non-Deductible unless they meet specific criteria under PMK 66/2023,.

Below is how PT SMA fills the Nominative List of Entertainment Expenses (Attachment 11A Part II) for Transactions A and B in Coretax:

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

Table Format Reference: Based on Attachment 11A of PER-11/PJ/2025,,.

Impact of Filling Errors

In the integrated Coretax system, data validity is crucial. Here are the consequences if the Nominative List is not created or filled incorrectly:

1. Positive Fiscal Correction: If entertainment costs are recorded as expenses in the Commercial P&L but do not appear in the Nominative List in Coretax (or if the Taxpayer answers "No" to the attachment completeness question despite having expenses), the costs will be automatically fiscally corrected. This means taxable income increases, and the tax payable becomes higher.
2. System Validation: Coretax uses pre-validation logic. In the Main SPT, there is a question: "Does the Taxpayer claim entertainment expenses...?". If answered YES, Attachment 11A (Corporate) or 3D (Individual) must be filled. If left blank, the SPT cannot be submitted,.
3. Data Analytics: Business relation data (NPWP/Name) inputted in the nominative list becomes feeding data for the DGT to analyze counterparties (cross-confirmation) through the Compliance Risk Management (CRM) system.

Filling Mechanisms in the Coretax Application

Taxpayers have two options for filling this list in the Coretax portal:

1. Key-In (Direct Input): Suitable for Taxpayers with few transactions. Users click the "Add" button in Attachment 11A/3D and fill in the pop-up form according to the columns in Table 1 above.
2. Data Import (XML/Excel): Suitable for companies with hundreds of entertainment transactions.
   • Taxpayers download the Excel/XML template provided by DGT.
   • Fill in the data offline.
   • Convert to XML (if using Excel) and upload it to the SPT Attachment menu.
   • Coretax performs automatic format validation.

Conclusion

The latest format of the Nominative List of Entertainment Expenses in Coretax demands higher transparency and detail compared to the previous system. The standardized table format in PER-11/PJ/2025 requires Taxpayers to record "Who", "Where", "When", and "For What" the expenses were incurred in detail.

The key to successful reporting in Coretax is administrative discipline. Companies are advised to record business relation details (Name, Position, Company) every time an entertainment expense occurs so that at the end of the tax year, the filling or data import process into Coretax runs smoothly without the risk of fiscal correction.