Latest Format of Private Offshore Debt Report (Attachment 11C) in Coretax Annual Tax Return

Introduction

In the era of global financial transparency and the implementation of the Core Tax Administration System (Coretax), cross-border transaction monitoring has become increasingly stringent. One of the Directorate General of Taxes (DGT) main focuses is monitoring foreign debts held by Corporate Taxpayers.

For Corporate Taxpayers, holding private offshore debt entails specific reporting obligations in the Annual Tax Return (SPT Tahunan). In the Coretax system, this reporting is no longer scattered or manual but structured in a standardized digital form, namely Attachment 11C (Lampiran 11C).

This article will detail the format, filling procedures, and case illustrations of the Private Offshore Debt Report based on the latest regulation PER-11/PJ/2025.

Legal Basis and Regulatory Reference

The formulation and reporting obligations are based on the following regulations:

1. Minister of Finance Regulation Number 81 of 2024: Regarding Tax Provisions for the Implementation of the Core Tax Administration System.
2. Director General of Taxes Regulation Number PER-11/PJ/2025: Concerning the Form, Content, and Procedures for Filling Annual Income Tax Returns. This regulation specifically governs the data structure of Attachment 11C.
3. Minister of Finance Regulation Number 169/PMK.010/2015: Regarding the Determination of Debt to Equity Ratio for Income Tax Calculation Purposes (Related to DER which is the basis for filling Attachment 11B before proceeding to 11C).

Relationship between Attachment 11B and Attachment 11C

In the Coretax ecosystem, Attachment 11C does not stand alone. It is a follow-up to the filling of Attachment 11B (Calculation of Deductible Borrowing Costs).

In Attachment 11B Part III, there is a crucial question: "Do you have private offshore debt?"

• • If the Taxpayer selects NO, then Attachment 11C does not need to be filled.
• • If the Taxpayer selects YES, the Coretax system requires the detailed filling of Attachment 11C. Without this, the Annual SPT will be considered incomplete and cannot be submitted.

Table Format of Private Offshore Debt Report (Attachment 11C)

Based on the Appendix in PER-11/PJ/2025, the following is the data structure (columns) that must be filled by Corporate Taxpayers holding foreign debt. This data must be presented in Rupiah (or USD if bookkeeping is in USD).

Table 1: Data Structure of Attachment 11C in Coretax

Important Notes:

• Exchange Rate Conversion: If bookkeeping is in Rupiah, foreign currency values must be converted to Rupiah. For the ending balance, use the exchange rate applicable at the end of the book year (according to accounting standards, usually BI Middle Rate for commercial or Tax Rate if specific provisions apply, but generally balance sheet reporting uses the balance sheet date rate).
• Related Party: If the creditor is a related party, ensure this data is consistent with Attachment 10A (List of Affiliated Transactions).

Case Illustration

To clarify the filling method, let's use the following case study.

Case Scenario: PT Manufaktur Global Indonesia

Profile:

• PT Manufaktur Global Indonesia (PT MGI) is a textile company in Bandung.
• Bookkeeping Currency: Rupiah (IDR).
• Tax Year: January - December 2025.

Offshore Debt Data: In 2025, PT MGI holds a long-term loan from Singa Finance Ltd. based in Singapore for purchasing new factory machinery.

• Loan Currency: US Dollar (USD).
• Principal Start (Jan 1, 2025): USD 1,000,000.
• New Withdrawals: None.
• Principal Payment (Installment): USD 200,000 (paid July 1, 2025).
• Interest: 5% per annum (Fixed). Total interest expense for 2025 is USD 45,000.
• Purpose: Purchase of Production Machinery.
• Agreement Date: Jan 1, 2023 to Jan 1, 2028.

Exchange Rate Data (Assumption):

• Start of Year Rate (Jan 1, 2025): Rp15,000 / USD.
• Payment Transaction Rate (July 1, 2025): Rp15,200 / USD.
• End of Year Rate (Dec 31, 2025): Rp15,500 / USD.

Calculation for Coretax (IDR Conversion):

1. Beginning Balance: USD 1,000,000 x Rp15,000 = Rp15,000,000,000 (Usually taken from last year's ending balance).
2. Reduction Mutation: USD 200,000 x Rp15,200 = Rp3,040,000,000.
3. Ending Balance (Forex): USD 1,000,000 - USD 200,000 = USD 800,000.
4. Ending Balance (IDR Reporting): USD 800,000 x Rp15,500 (End Rate) = Rp12,400,000,000. (Forex differences due to monetary translation will go to the Forex Gain/Loss account in the Income Statement).
5. Interest Amount: USD 45,000 x Rp15,250 (Assumed Avg Rate) = Rp686,250,000.

Below is the Attachment 11C filling display by PT MGI in Coretax:

Table 2: Filling Illustration in Coretax (Attachment 11C)

Note: Number columns are filled without thousand separators in the system (numbers only).

Risk Analysis and Impact in Coretax

Filling Attachment 11C in Coretax is not just an administrative formality. The system integrates with the Compliance Risk Management (CRM) module. Here are the implications:

1. DER Validation (Attachment 11B)

The "Interest Amount" and "Debt Balance" data in Attachment 11C will be matched with Attachment 11B. If the Debt to Equity Ratio (DER) exceeds 4:1 (per PMK 169/2015), the system will automatically calculate the portion of interest expense from this foreign debt that is Non-Deductible. Inconsistency between figures in 11C and 11B can trigger an audit flag.

2. Transfer Pricing Supervision

If the "Creditor" is indicated as a related party, data in 11C will be cross-checked with Attachment 10 (Affiliated Transactions) and Transfer Pricing Documentation (TP Doc). The DGT will assess whether the interest rate (5% in the example above) is at arm's length compared to market rates.

3. Consistency with Withholding Tax (PPh 26)

The Coretax system integrates Annual SPT data with Periodical SPT (SPT Masa). The DGT will verify: Has PT MGI withheld and remitted Income Tax Art. 26 (usually 20% or Treaty Rate) on the interest payment of Rp686,250,000? If there is offshore interest expense in Attachment 11C, but no PPh 26 withholding proof reported in the Unified Periodical SPT, this will become an automatic finding.

Conclusion

The format of the private offshore debt report (Attachment 11C) in the Coretax Annual Tax Return demands a high level of accuracy and detail. Taxpayers are not just reporting balances, but also mutations, interest, and fund allocation in Rupiah/functional currency.

The keys to successful reporting are:

1. Data Reconciliation: Ensure figures in Attachment 11C match the Balance Sheet (L1), Interest Expense in P&L (L1), and DER Calculation (L11B).
2. Withholding Tax Compliance: Ensure PPh Art. 26 obligations on interest have been met before filing the Annual SPT.
3. Documentation: Keep loan agreements and interest payment proofs in anticipation of audits, especially if related parties are involved.

References

1. Director General of Taxes Regulation Number PER-11/PJ/2025 concerning the Form, Content, and Procedures for Filling Annual Income Tax Returns.
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 regarding the Determination of Debt to Equity Ratio for Income Tax Calculation Purposes.