Types of Income Tax Returns in the Implementation of the Global Minimum Tax in Indonesia

In response to the OECD Pillar Two agreement, Indonesia has issued Minister of Finance Regulation (PMK) Number 136 of 2024 and Director General of Taxes Regulation Number PER-6/PJ/2026. These regulations require Multinational Enterprise (MNE) Groups with a consolidated gross revenue of at least EUR 750 million to comply with a 15% global minimum tax. To accommodate this tax reporting domestically, the tax authority formulated a new reporting document outside of the conventional Corporate Income Tax Return, called the "Annual Income Tax Return for the implementation of GloBE" (SPT Tahunan PPh dalam rangka melaksanakan GloBE).

Based on its administrative structure, the Annual Income Tax Return for the implementation of GloBE is divided into three specific types of reporting, namely:

1. GloBE Annual Income Tax Return (SPT Tahunan PPh GloBE):

   This return is specifically required for GloBE Taxpayers holding the status of Ultimate Parent Entity (UPE) that are domestic tax subjects in Indonesia. This instrument contains comprehensive aggregate data on the calculation of top-up taxes based on the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR) per jurisdiction, and the Domestic Minimum Top-up Tax (DMTT) in Indonesia.

2. DMTT Annual Income Tax Return (SPT Tahunan PPh DMTT):

   This instrument is mandatory and must be submitted by every GloBE Taxpayer (Constituent Entity) domiciled in Indonesia, whether a parent entity or a subsidiary. This return is used to report domestic top-up tax obligations if the Effective Tax Rate (ETR) of their operations in Indonesia falls below the 15% minimum rate.

3. UTPR Annual Income Tax Return (SPT Tahunan PPh UTPR):

   This return must be filled out by GloBE Taxpayers in Indonesia (other than the Ultimate Parent Entity) only in the event that there is an allocation of top-up tax based on the UTPR charged to the Indonesian jurisdiction as a global backstop.

Administratively, these three types of tax returns must be submitted no later than 4 (four) months after the end of the GloBE Tax Year. However, specifically for the first GloBE Fiscal Year, Taxpayers are granted an extension facility for submission of 2 (two) months. The filing of this return also strictly requires Taxpayers to attach the receipt of the centralised GloBE Information Return (GIR) submission or local Notification.