Executive Summary
This article comprehensively discusses the Value Added Tax (VAT) provisions on the Export of Taxable Services (JKP) in Indonesia, which are subject to a 0% rate to support global competitiveness. The discussion covers the definition, the three main categories of services qualifying for export, formal requirements for agreements and proof of payment, and the obligation to generate a Service Export Declaration (PEJ) document, which serves as an equivalent to a Tax Invoice. Following the implementation of the Core Tax Administration System (Coretax), the reporting procedure and PEJ format are now fully integrated electronically through the Taxpayer Portal.
The Export of Taxable Services (JKP) refers to any delivery of Taxable Services generated within the Customs Area for utilization by an export recipient outside the Customs Area. To encourage national exports and maintain tax neutrality, the government applies a 0% (zero percent) Value Added Tax (VAT) rate on the export of these services. The application of a 0% rate does not imply tax exemption; therefore, the Input Tax paid on the acquisition of goods or services related to these export activities remains creditable by the Taxable Entrepreneur (PKP).
Categories of Exportable Taxable Services
In accordance with tax regulations, service activities categorized as JKP Exports are divided into three main groups:
- Activities attached to movable goods: These are designated for goods that will be utilized outside the Customs Area, which include toll manufacturing services (maklon), repair and maintenance services, and freight forwarding services related to export-bound goods. Specifically for toll manufacturing, the specifications and raw materials must be provided by the export recipient, ownership of the goods rests with the recipient, and the finished goods must be sent outside the Customs Area.
- Activities attached to immovable goods: These include construction consulting services (assessment, planning, and design) related to buildings or building plans located outside the Customs Area.
- Other service activities: The results of these activities are delivered for utilization outside the Customs Area via direct/indirect delivery (such as electronic channels) or the provision of access rights. These services include IT services, research and development, aircraft/ship leasing for international flights or voyages, interconnection/satellite services, trade services (finding domestic sellers for export purposes), and various consulting services such as business, management, legal, design, engineering, accounting, audit, and tax.
Requirements for the 0% VAT Rate
The 0% VAT rate on JKP Exports does not apply automatically. The PKP must fulfill the following cumulative requirements:
- There must be a written agreement or contract between the PKP and the JKP Export Recipient clearly stating the type of service, details of activities generated within the Customs Area to be utilized outside, and the delivery value.
- There must be a payment accompanied by valid proof of payment from the JKP Export Recipient to the PKP in Indonesia.
If the service activity fails to meet these two requirements, the transaction is deemed a domestic delivery of JKP and is subject to the standard VAT rate. Services generated and utilized entirely outside the Customs Area are not subject to VAT.
Time of Supply and Service Export Declaration (PEJ) Document
VAT on JKP Exports is due when the replacement value for the exported service is recorded or recognized as a receivable or income. At this precise moment, the PKP is obligated to issue a tax collection evidence document.
In JKP export transactions, the Tax Invoice used is a specific document equivalent to a Tax Invoice, namely the Export Declaration of Intangible Taxable Goods or Taxable Services, which must be attached with a sales invoice as an inseparable unit. With the implementation of the Core Tax Administration System (Coretax), this export declaration document must be created electronically through the Taxpayer Portal or other platforms integrated with the Directorate General of Taxes administration system.
Format of the Taxable Service Export Declaration
The Service Export Declaration (PEJ) document is systematically designed to capture the essential information of international transactions. Based on the reporting guidelines, the PEJ format contains the following details:
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Exporter Identity:
Includes the Name, Address, and Taxpayer Identification Number (NPWP) of the PKP exporting the service.
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Client/Recipient Identity:
Includes the Name, Overseas Address, Country/City/Zip Code, Phone Number, and NPWP or Tax Identification Number (TIN) of the foreign receiving entity.
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Details of Taxable Services:
Specific clarification on whether the service is "Toll Manufacturing" or "Non-Toll Manufacturing", accompanied by service descriptions, contract/agreement number and date, and sales invoice number and date. For toll manufacturing services, the Export Declaration of Goods (PEB) reference number must also be included.
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Tax Base Details:
Contains the Selling Price or Replacement Value, Tax Base (DPP), and the VAT owed.
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Electronic Endorsement:
The document includes a statement of accountability for the data, which is signed electronically (Electronic Signature) through the DJP system, thereby eliminating the need for a wet signature.
These JKP Export activities must be reported by the PKP in the Periodic VAT Return (SPT Masa PPN). Specifically for toll manufacturing services, in addition to reporting the JKP export, the PKP must also report the export of the resulting BKP (Taxable Goods) in the Periodic VAT Return.
List of Tax Regulation References
- Law Number 8 of 1983 concerning Value Added Tax on Goods and Services and Sales Tax on Luxury Goods, as lastly amended by Law Number 6 of 2023.
- Minister of Finance Regulation Number 81 of 2024 concerning Tax Provisions in the Context of Implementing the Core Tax Administration System.
- Director General of Taxes Regulation Number PER-11/PJ/2025 concerning Reporting Provisions for Income Tax, Value Added Tax, Sales Tax on Luxury Goods, and Stamp Duty in the Context of Implementing the Core Tax Administration System.