Tax Reporting Transformation: Employers Now Required to Attach List of Assets Related to Benefits in Kind in Coretax Corporate Income Tax Return

Introduction

The implementation of the Core Tax Administration System (Coretax) brings fundamental changes to tax reporting procedures in Indonesia. One significant change that Corporate Taxpayers must understand is the reporting mechanism for Benefits in Kind (Natura dan/atau Kenikmatan). Since the enactment of Minister of Finance Regulation Number 66 of 2023, the tax paradigm for remuneration in the form of benefits in kind has shifted from Non-Deductible Non-Taxable to Deductible Taxable. This means that costs related to benefits in kind can now be expensed by the company (deductible) provided that the benefit is a taxable object for the recipient (employee).

To accommodate this change and ensure the validity of depreciation expense claims on assets used to provide benefits (such as company cars, official housing, gym facilities, etc.), the Directorate General of Taxes (DGT) through the Coretax system requires specific attachment filling. In the latest Corporate Income Tax Return (SPT Tahunan PPh Badan) format (based on PER-11/PJ/2025), employers must detail these assets in Attachment 11A Part IV.A (Lampiran 11A Bagian IV.A).

This article will thoroughly explore the filling technique, table format, and case illustrations so that companies can mitigate reporting error risks that could lead to fiscal corrections.

Legal Basis and Regulatory Reference

This reporting obligation is based on the latest regulatory framework governing Coretax implementation:

1. Minister of Finance Regulation Number 81 of 2024 concerning Tax Provisions for the Implementation of the Core Tax Administration System.
2. Director General of Taxes Regulation Number PER-11/PJ/2025 regarding the Form, Content, and Procedures for Filling Unified Periodical Income Tax Returns, Periodical Value Added Tax Returns, and Annual Income Tax Returns.
3. Law Number 7 of 1983 concerning Income Tax as amended by the Harmonization of Tax Regulations Law (HPP).

Trigger Mechanism in Coretax

In the Coretax system, tax return forms are dynamic. Attachment 11A will not appear automatically but is triggered by the Taxpayer's answer in the Master Tax Return (Formulir Induk).

In section H. Transaction Statement of the Corporate Income Tax Return Master file, there is a crucial question:

"21.f. Does the Taxpayer claim entertainment expenses, promotion and sales expenses, reimbursement or remuneration in the form of natura and/or benefits in kind, and uncollectible receivables?".

If the Taxpayer answers "YES", the Coretax system will automatically require the filling of Attachment 11A - Details of Certain Expenses. Inside this Attachment 11A is Part IV, which specifically handles "Details for Taxpayers Providing Natura and/or Benefits in Kind".

Format of List of Assets Related to Benefits in Kind (Attachment 11A Part IV.A)

This section is designed to record company assets whose useful life is enjoyed by employees. The validity of depreciation expenses deducted from the company's gross income will be tested through this list.

Based on the Appendix of PER-11/PJ/2025, here are the details of the columns that must be filled,:

Table 1: Data Structure of Natura/Benefits Asset List in Coretax

Important: The data in this table serves as a cross-validation tool. The DGT will compare:

1. Total depreciation in this Attachment 11A.
2. Total depreciation in Attachment 9 (List of Fiscal Fixed Asset Depreciation).
3. The value of natura income reported in the employee's Withholding Tax Slip (Bukti Potong PPh 21) (whether the benefit of the official car has been taxed on the employee's side).

Case Illustration

To provide a more concrete picture, let's look at the following case study.

Scenario: PT Maju Sejahtera Bersama

PT Maju Sejahtera Bersama is a manufacturing company. In the 2025 Tax Year, the company provides the following facilities to its employees:

1. Director's Official Car: A sedan purchased in January 2023 for IDR 800,000,000. Useful life 8 years (Group 2). This car is taken home and fully used by the Marketing Director.
2. Official Apartment: The company purchased an apartment unit in January 2020 for IDR 1,500,000,000 (Permanent Building, useful life 20 years) for the residence of an expatriate General Manager.
3. Operational Laptop: Laptops given to the sales team for work (not a natura enjoyed for pure personal interest, but a work tool).

Tax Treatment Analysis (PMK 66/2023 & Coretax):

• Official Car: Because it is enjoyed by specific employees, the depreciation cost of this car is Deductible for the company. However, the company must report it in Attachment 11A Part IV.A. On the other hand, the benefit value of this car must be calculated and PPh 21 withheld from the Director's salary.
• Apartment: Same as the car, the depreciation of the apartment building is Deductible and must be listed in Attachment 11A Part IV.A.
• Laptop: Since it is a mandatory work tool (not a fringe benefit), this asset does not need to be entered into Attachment 11A Part IV (Natura), but sufficiently in Attachment 9 (Regular Fixed Asset List), as it is not a PPh object for the employee (excluded from natura objects).

Fiscal Depreciation Calculation (Straight Line Method):

1. Car: IDR 800,000,000 / 8 years = IDR 100,000,000 per year.
2. Apartment: IDR 1,500,000,000 / 20 years = IDR 75,000,000 per year.

Here is how PT Maju Sejahtera Bersama fills Attachment 11A Part IV.A in Coretax:

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

Calculation Notes:
• Car (2023, 2024): 100m x 2 = 200m (up to last year). Year 2025 = 100m.
• Apartment (2020-2024): 75m x 5 = 375m (up to last year). Year 2025 = 75m.

Relationship with Other Attachments in Coretax

Filling out the table above does not stand alone. The integrated Coretax system will validate the logic with other parts:

1. Attachment 9 (List of Fiscal Depreciation & Amortization): The total depreciation in Attachment 11A Part IV.A is a subset of the total depreciation in Attachment 9,. This means if the company's total fiscal depreciation is IDR 1 Billion, and IDR 175 Million of it is natura assets (table above), then the difference is purely operational assets.
2. PPh 21 Withholding Slips: In Coretax, withholding data is also integrated. The DGT can analyze whether the facility value of IDR 175,000,000 (depreciation expense this year) has been reasonably reflected in the gross income of the employees receiving the facility in their PPh 21 Tax Return.

Implications for Taxpayers

With this new format in Coretax, Taxpayers need to take mitigation steps:

1. Asset Inventory: Perform tagging or special marking on the company's Fixed Asset Register. Separate purely operational assets from assets given as facilities (benefits) to employees.
2. Policy Consistency: Ensure the policy of providing natura is consistent with PPh 21 reporting. If car depreciation costs are claimed in Attachment 11A, ensure there is a car natura component in the Director's PPh 21.
3. Documentation: Keep a nominative list of facility recipients. Although Attachment 11A Part IV.A asks for the asset list, Part IV.B (for specific areas) or a tax audit might request user details.

Conclusion

The obligation to attach a List of Facilities (Natura Assets) in the Corporate Annual Tax Return in Coretax is a manifestation of tax transparency. The table format in Attachment 11A forces Taxpayers to be more disciplined in sorting assets. Errors in filling can trigger risk indicators (risk engine) in the DGT supervision system. Therefore, technical understanding of PER-11/PJ/2025 and data integration between assets and payroll are keys to compliance in the Coretax era.