Transparency Transformation: The Newest Format of Natura and Benefit in Kind Nominative List in Coretax Annual Tax Return

Introduction

The implementation of the Core Tax Administration System (Coretax System) brings a digital revolution to the Annual Income Tax Return (SPT Tahunan) reporting procedures. One of the most significant changes lies in the standardization of reporting costs for Reimbursement or Compensation in the form of Natura (In-Kind) and/or Kenikmatan (Benefits/Facilities).

Since the enactment of the Harmonization of Tax Regulations Law (UU HPP) and its derivative regulations (GR 55 of 2022), the Taxability-Deductibility principle has reshaped the landscape of natura taxation. Natura costs are now deductible for the employer but simultaneously become taxable objects for the recipient (employee), except for specific exempted natura types.

In the legacy system, Taxpayers often attached nominative lists in non-uniform PDF or Excel formats. However, in the Coretax ecosystem, this reporting must be entered into structured data forms that have logical validation and are integrated with Article 21 Income Tax withholding proofs. This article will thoroughly explore the new format based on the latest regulation PER-11/PJ/2025.

I. Legal Basis and Regulatory References

The format and procedures for filling out this nominative list refer to the following provisions:

• Minister of Finance Regulation Number 81 of 2024 concerning Tax Provisions in the Framework of Implementing the Core Tax Administration System.
• Director General of Taxes Regulation Number PER-11/PJ/2025 regarding the Form, Content, and Procedures for Filling Periodic and Annual Tax Returns. This regulation specifically governs the column details and data validation in the Coretax Annual Tax Return Attachments,.
• Government Regulation Number 55 of 2022 concerning Adjustment of Regulations in the Field of Income Tax.

II. Form Locations in Coretax

In the Coretax system, the location for filling out the natura nominative list differs depending on the type of Taxpayer. Below is the location mapping:

Table 1: Natura Nominative List Form Locations

III. Data Format and Filling Procedures

Coretax demands precise detail. Unlike the old system, the "Description" column now has a standard syntax that must be followed for the system to read the data correctly. Additionally, there is an integration with the Article 21 Income Tax withholding slip number.

Table 2: Column Structure and Filling Instructions for Nominative List (Attachment 11A Part I / Attachment 3D Part B)

The following table details every column that must be filled by the Taxpayer when performing input (key-in) or XML data import in Coretax,,,,.

Table 3: Facility Asset Detail Column Structure (Attachment 11A Part IV.A)

This section is mandatory to fill by Corporate Taxpayers if the natura value in Table 2 comes from the use of company-owned assets (not rented from third parties), such as official cars or official houses owned by the company,,,.

IV. Case Illustration and Application in Coretax Tables

To clarify the filling technicalities, a comprehensive case study is presented below.

Taxpayer Profile:

• Name: PT. Teknologi Masa Depan (TMD).
• Tax Year: 2025.
• Status: Taxable Entrepreneur (PKP).

Natura/Benefit Transactions in 2025:

1. Apartment Facility (Rental): PT. TMD rents an apartment for Mr. Roy (Director) to live in for a year. The rental fee paid to the apartment owner is IDR 120,000,000. According to regulations, this is an Article 21 Tax Object. Article 21 Tax has been withheld via Mr. Roy's A1 Withholding Slip.
2. Official Car (Company Asset): PT. TMD provides an operational sedan car (owned by PT) which is taken home by Mrs. Sinta (Sales Manager). The car was purchased in 2023 for IDR 400,000,000 (Group 2, Straight Line). The 2025 fiscal depreciation cost is IDR 50,000,000. This is an Article 21 Tax Object.
3. Holiday Hamper: PT. TMD gives holiday hampers (groceries/food ingredients) to all employees, including Mr. Budi (Staff). The hamper value is IDR 500,000. Based on PMK 66/2023, religious holiday hampers are Non-PPh Objects (exempted).

Table 4: Simulation of Filling Attachment 11A - Part I (Nominative List)

Here is how PT. TMD fills out the form in Coretax based on the transactions above:

Table 5: Simulation of Filling Attachment 11A - Part IV.A (Asset Details)

Because in Entry 2 (Mrs. Sinta's Official Car) the benefit provided comes from company assets, PT. TMD must fill out this additional table to validate the IDR 50,000,000 figure claimed in Part I.

> Note: The "Depreciation This Year" value (50 Million) in Table 5 is the basis for the "Value" figure in Table 4 for Mrs. Sinta's row.

V. Conclusion and Critical Points

The change in the Natura Nominative List reporting format in Coretax is not just a visual update, but a strengthening of supervision functions (compliance risk management). Taxpayers need to pay attention to the following:

1. Description Format: The use of the syntax "Form - Account - Status" in the Description column is mandatory. Formatting errors can make it difficult for the system to validate data,,.
2. Bupot Integration: The Withholding Proof Number column forces Taxpayers to ensure that every natura cost claimed as a deductible expense (deductible) has had its tax withheld (taxable) on the employee's side through the Article 21 PPh e-Bupot mechanism, unless explicitly stated as non-object.
3. Asset Data Consistency: For natura in the form of company asset facilities, the value reported in the Nominative List (Part I) must synchronize with the current year's fiscal depreciation value reported in Part IV.A.

Failure to fill out this form correctly and completely may result in the Annual Tax Return being considered incomplete or triggering a tax audit due to indications of non-compliance in tax withholding (equalization of costs vs Article 21 PPh objects).