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Decision

A Desicion in tax matters is the final outcome from the Tax Court regarding a dispute between you (the Taxpayer) and the Directorate General of Taxes. It is the final legal decision that determines whether your appeal or lawsuit is accepted or rejected. This decision ultimately establishes the amount of tax you are legally required to pay.

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

When VAT Rules Utterly Fail: Tax Court Overturns Foreign-Utilized VAT Royalty Correction Due to his Mistake Made by the DJP

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-000820.16/2020/PP/M.XIA Of 2024 – 11 November 2024

The implementation of the Arm’s Length Principle (ALP) in transfer pricing disputes frequently creates a domino effect on other tax types, particularly Value Added Tax (VAT).

Decision
April 04, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Against IDR 3.8 Billion VAT Correction: Judges Cancel Account Receivable Assumption Without Tax Invoice Evidence

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-002998.16/2024/PP/M.XA Of 2025 – 24 September 2025

Decision
April 04, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Rejecting the DJP's Formal Reasons: The Panel of Judges Granted the Taxpayer's Appeal Against Article 26 Income Tax Thanks to Valid DGT-1 Evidence

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Partially Granted

PUT-003062.13/2024/PP/M.IA Of 2025 – 24 September 2025

Decision
April 04, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Dual Bank Loan Trap: Tax Court Decision Affirms Interest Expense for Final Tax Projects Must Be Corrected!

Tax Court Decision | Annual Corporate Income Tax | Appeal | To Reject the Appeal/ Lawsuit

PUT-002448.15/2022/PP/M.IVB Of 2025 – 25 September 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Strategic or Not? Why Palm Kernel Expeller Sales to Exporters Remain Subject to VAT

Tax Court Decision | PPN | Appeal | To Reject the Appeal/ Lawsuit

PUT-002117.16/2024/PP/M.XIVB Of 2025 – May 15 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Appeal Strategy: Unveiling the Fact of Realized Cost Provisions Previously Corrected

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-002152.15/2024/PP/M.XXA Of 2025 – 22 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Complete Victory! How PT PK Nullified Billions in Revenue Correction Based Solely on Cash Flow Estimates

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-015139.15/2020/PP/M.XB Of 2025 – 27 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Media Rebates Aren't Management Services? Discover PT DIAMGI's Landmark Victory at the Tax Court!

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-002157.16/2024/PP/M.XXA Of 2025 – 22 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Profit Margins Below the Arm's Length Range? Learning from PT SLM's Failure to Prove the Impact of Gas Prices and Imports in the Tax Court

Tax Court Decision | Annual Corporate Income Tax | Appeal | To Reject the Appeal/ Lawsuit

PUT-002294.15/2023/PP/M.XIIIB Of 2025 – 20 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Challenging a Tax Collection Letter Based on a Section Head's Signature? Take a Look of These Tax Court Judicial Considerations

Tax Court Decision | Tax Lawsuit | Lawsuit | To Reject the Appeal/ Lawsuit

PUT-011578.99/2023/PP/M.XIVA Of 2025 – 11 June 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Hidden Risks of Interest-Free Loans to Parent Companies: Lessons from the PT MGR Case

Tax Court Decision | Annual Corporate Income Tax | Appeal | To Reject the Appeal/ Lawsuit

PUT-012651.15/2022/PP/M.XVIIIA Of 2025 – 10 June 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Trapped by the 5-Year Rule: Why Natural Timber Sales Could Not Save PT PBA’s Input Tax Credits?

Tax Court Decision | PPN | Appeal | To Reject the Appeal/ Lawsuit

PUT-002373.16/2024/PP/M.IXA Of 2025 – 26 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

A Comprehensive Victory: How PT OTS Successfully Challenged Indirect Audit Methods in Tax Court

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

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Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Checking the Fine Print: How a Calculation Error Altered The TAXPAYERs VAT Obligation 

Tax Court Decision | PPN | Appeal | To Amend

PUTP1-004058.16/2023/PP/M.XIVB Of 2025 – 12 June 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Beware! VAT Base Corrected as “Nil” Thanks to Return Notes and Ledgers: The Key to The Taxpayer's Victory Against the DJP's Cash Flow Test

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-003236.16/2024/PP/M.IIIA Of 2025 – 22 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Appeal Strategy: Countering Accumulative Corrections to Income Tax Article 26 Through the Argument of the Expiration of the Determination

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Fully Granted

PUT-003067.13/2023/PP/M.XIIA Of 2025 – 19 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Free Drinking Water for Employees: A Valid VAT Credit According to the Tax Court

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-003923.16/2024/PP/M.XA Of 2025 – 14 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Discrepancies in Tax Court Figures? How Judges Rectify Errors via Fast-Track Procedures 

Tax Court Decision | Annual Corporate Income Tax | Judicial Review of an Appeal Decision | To Amend

PUT-005424.15/2022/PP/M.XIVB Of 2025 – 12 June 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Income Tax Article 26 Constructive Dividend Trap is Cancelled! Tax Court Rejects DJP's Correction Due to Failed Comparability Test of the Trading Function

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | Fully Granted

PUT-003247.13/2024/PP/M.IIIA Of 2025 – 22 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Warning! Representative Offices Could Face Billions in Taxes Due to the "Force of Attraction" Rule on Head Office Sales

Tax Court Decision | Income Tax Article 15 (Final) Appeal | To Reject the Appeal/ Lawsuit

PUT-005632.27/2023/PP/M.XIIA Of 2025 – 26 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Big at Tax Court: Why Supplemental Evidence Can Still Overturn Multimillion-Dollar Corrections

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-007115.16/2020/PP/M.XIA Of 2025 – 21 April 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Wins IDR 9.6 Billion: Why the DJP Lost Completely in Tax Court Over CIT SKPLB Correction?

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-007898.15/2024/PP/M.XVA Of 2025 – 8 September 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Director's Cash Deposits as Taxable Revenue? Lessons from the PT SSA Tax Court Win

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-007418.16/2024/PP/M.IXA Of 2025 – 26 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Tax Double Jeopardy Trap: Intra-Group Service Fees Rejected in Income Tax, Input VAT Goes Up in Smoke!

Tax Court Decision | PPN | Appeal | To Reject the Appeal/ Lawsuit

PUT-009755.16/2023/PP/M.XIB Of 2025 – 24 September 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Is Construction Certification Stronger Than the New Law? Analysis of the Taxpayer’s Defeat in the Final Income Tax Dispute over Submarine Cable Installation

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | To Reject the Appeal/ Lawsuit

PUT-003954.12/2023/PP/M.IVA Of 2025 – 20 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

A SAP Currency Input Error Led to a IDR 27 Billion Tax Correction for PT TDASI: How Did the Judges Rule?

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | Fully Granted

PUT-008058.12/2020/PP/M.XIA Of 2025 – 29 April 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

DJP Misconception on Freight Forwarding as Ship Charter: PT PGL Wins Landslide Victory in Tax Court!

Tax Court Decision | Income Tax Article 15 (Final) Appeal | Fully Granted

PUT-006676.27/2024/PP/M.XIB Of 2025 – 25 September 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Wrong Legal Path: Why PT SCP’s Lawsuit to Cancel the Tax Assessment Was Rejected?

Tax Court Decision | PPN | Lawsuit | To Reject the Appeal/ Lawsuit

PUT-008095.99/2023/PP/M.XIB Of 2025 – 21 Mei 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Expat Salaries Corrected by the DJP? Beware, Proof of "Reimbursement" Transfer Can Turn Back on You!

Tax Court Decision | PPN | Appeal | To Reject the Appeal/ Lawsuit

PUT-014742.16/2020/PP/M.XIA Of 2025 – 25 September 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Beware! Why Did PT IB Fail to File a Lawsuit Before Being Examined by the Tax Court?

Tax Court Decision | Tax Lawsuit | Lawsuit | The Petition is Inadmissible

PUT-009112.99/2024/PP/M.VIIIA Of 2025 – 26 May 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Failed to Prove a IDR 3.8 Billion Cost Discrepancy, Article 23 Tax Appeal Rejected: Crucial Lesson from the Tax Court Decision

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | To Reject the Appeal/ Lawsuit

PUT-009745.12/2023/PP/M.XIB Of 2025 – 24 September 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning VAT Appeals: Challenging Corrections Without SPHP and Invoice Confirmation Issues

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-009469.16/2020/PP/M.XIA Of 2025 – 29 April 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning VAT Appeals: Challenging Corrections Without SPHP and Invoice Confirmation Issues

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-009469.16/2020/PP/M.XIA Of 2025 – 29 April 2025

Decision
April 02, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Defeating the DJP: Prior Year's Withholding Slips Cannot Be the Basis for Current Year's VAT Base Correction

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-006694.16/2024/PP/M.XIB Of 2025 – 25 September 2025

Decision
April 02, 2026 • Taxindo Prime Consulting

The PPh 26 Formality Trap: Key Lessons from the PT AA Decision Testing the Limits of SKD Evidence Tolerance 

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Partially Granted

PUT-003057.13/2024/PP/M.IA Of 2025 – 24 September 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Fine Line Between Preparation and Sales: When a Foreign Representative Office is Deemed a PE and All Head Office Exports Become Taxable

Tax Court Decision | Income Tax Article 15 (Final) To Reject the Appeal/ Lawsuit

PUT-005655.27/2023/PP/M.XIIA Of 2025 – 26 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Tax Equalization Trap: International Representative Office Fails to Overturn Income Tax Article 23 in the Tax Court Due to This Mistake

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | To Reject the Appeal/ Lawsuit

PUT-005643.35/2023/PP/M.XIIA Of 2025 – 26 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Unpaid Foreign Loan Interest Still Subject to WHT Article 26: Tax Court Rules Legal Due Date Overrides Actual Cash Payment

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | To Reject the Appeal/ Lawsuit

PUT-001936.13/2022/PP/M.XIVB Of 2025 – 9 July 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

No Payment, No Withholding Tax: How a Taxpayer Won a Major WHT Article 26 Secondary Adjustment Dispute

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | Fully Granted

PUT-001936.13/2022/PP/M.XIVB Of 2025 – 28 July 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Beware! Affiliate Service Fees May Be Deemed Disguised Dividends by Tax Judges

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Partially Granted

PUT-010219.35/2022/PP/M.XXB Of 2024 – 19 September 2024

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Rp23 Billion Transfer Pricing Correction Annulled! Tax Court Sends Strong Message: DJP Cannot Arbitrarily Correct Domestic Transactions

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-007717.15/2023/PP/M.VA Of 2025 – 28 July 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Trap of Imputed Interest PPh 23 from Shareholders: When Does a Taxpayer Win by Proving Poor Liquidity?

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | Fully Granted

PUT-010258.12/2024/PP/M.XXA Of 2025 – 12 August 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Paid Foreign Service VAT but Accused of Hidden Dividend: This How PT BCI Fought Back and Won in The Tax Court

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-001590.16/2022/PP/M.XIIA Of 2025 – 16 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Article 26 WHT Correction Saga: Failure to Prove Service Benefit Leads to IDR 9 Billion Fee Reclassified as Deemed Dividend!

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | To Reject the Appeal/ Lawsuit

PUT-001584.13/2022/PP/M.XIIA Of 2025 – 16 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Due to Taxpayer’s Failure to Prove This, The Tax Court Rejected Its Appeal Even with Arm’s Length Profit

Tax Court Decision | Annual Corporate Income Tax | Appeal | Revocation

PUT-003798.15/2023/PP/M.XIIA Of 2025 – 16 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Wins Against WHT Article 26 Deemed Dividend: The Tax Court Sets the Boundary of Secondary Correction Authority in Transfer Pricing Disputes

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | Fully Granted

PUT-003808.35/2023/PP/M.XIIA Of 2025 – 16 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Lost on Corporate Tax, Won on Withholding Tax: How PT BCI Overturned the DJP's Deemed Dividend Correction

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Fully Granted

PUT-002213.13/2023/PP/M.XIIA Of 2025 – 16 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Input VAT Credit is Still Possible for 'Dormant' Companies: Key Lessons from a Tax Court Ruling

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-004955.16/2021/PP/M.XVIIIA Of 2025 – 16 September 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Crucial Lesson in Final Income Tax Dispute: End Customer Transactions Cannot Legally Serve as a Comparable for Sales to a Distributor

Tax Court Decision | Income Tax Article 4 Paragraph 2 (Final) | Appeal | Fully Granted

PUT-012998.25/2022/PP/M.XIIIA Of 2025 – 24 April 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Warning! Derivative VAT Correction from Transfer Pricing Totally Overturned in Tax Court: Crucial Lessons from the DJP’s Failed CUP Test

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-012997.16/2022/PP/M.XIIIA Of 2025 – 24 April 2025

Decision
April 01, 2026 • Taxindo Prime Consulting

Accounts Receivable Test Overruled for VAT: Why the IDR 1.2 Billion Corporate Income Tax Turnover Correction Is Not Automatically a VAT Object

Tax Court Decision | PPN | Appeal | Partially Granted

PUT-009760.16/2022/PP/M.XIIIA Of 2025 – 22 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Affiliate GPM Was Already Profitable, DJP Forces IDR 11.3 Billion COGS Correction by Reclassifying Costs: PT PLII’s Internal Comparable Strategy Wins Absolutely in the Tax Court

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-000018.15/2023/PP/M.IB Of 2025 – 19 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Total Victory! Tax Court Annuls DJP Income Tax Article 22 Base Correction: Volume Discounts Are Price Reductions, Not Awards

Tax Court Decision | Income Tax Article 22 (Non-Final) | Appeal | Fully Granted

PUT-000019.11/2023/PP/M.IB Of 2025 – 19 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Fighting the Income Tax Article 23 Trap on Back-End Discounts: The Tax Court Annuls DJP Correction Due to This Regulation It Used!

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | Fully Granted

PUT-000020.12/2023/PP/M.IB Of 2025 – 19 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Against Hundreds of Millions in VAT Corrections: The Success Story of PT PLII in Defending Back-End Discounts as a Reduction to the VAT Tax Base (DPP)

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-000023.16/2023/PP/M.IB Of 2025 – 19 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

IDR 4 Billion VAT Correction Overturned! Tax Court's Principle of Justice Prevails Over Formal Tax Invoice Code Requirements for Bonded Zones

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-000083.16/2018/PP/M.XVA Of 2019 – 25 February 2019

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Appeal Rejected Before Hearing Due to Failure to Meet This Requirement! A Crucial Lesson for Taxpayers in Tax Litigation

Tax Court Decision | Income Tax Article 4 Paragraph 2 (Final) | Appeal | To Reject the Appeal/ Lawsuit

PUT-000314.25/2020/PP/M.IIIA Of 2021 – 25 March 2021

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Failed DJP's Single Year Test: Tax Decision Affirms the Role of Pure Business Evidence and Multiple Years Analysis in Corporate Income Tax Transfer Pricing Disputes

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-000351.15/2021/PP/M.IVB Of 2025 – 8 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Beware! Promotion Expense Equalization Flagged as Income Tax Article 21 Object, How PT MCI Won the Appeal 

Tax Court Decision | Income Tax Article 21 (Non-Final) | Appeal | Fully Granted

PUT-011285.10/2021/PP/M.XXB Of 2024 – 19 September 2024

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Profit Correction Battles: Lessons from PT UI’s Transfer Pricing Dispute at the Tax Court

Tax Court Decision | Annual Corporate Income Tax | Appeal | Partially Granted

PUT-008845.15/2023/PP/M.IIIA Of 2025 – 15 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Tax Disputes on Reimbursement Costs: Lessons from the PT EMLI Case

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | Partially Granted

PUT-012263.12/2020/PP/M.IIA Tahun 2025 – 27 Mei 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Purchasing Limestone from "Local Communities" Remains Subject to Article 22 Tax Corrections?

Tax Court Decision | Income Tax Article 22 (Non-Final) | Appeal | To Reject the Appeal/ Lawsuit

PUT-008864.11/2023/PP/M.IIIA Of 2025 – 15 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Transfer Pricing Dispute: Why Was the DJP's Internal Valuation Overturned by the Tax Court?

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-009473.16/2022/PP/M.XIIB Of 2025 – 14 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Paid Taxes But Didn't File a Tax Return? Beware of 17 Months of Interest Penalties that Await You!

Tax Court Decision | Tax Lawsuit | Lawsuit | To Reject the Appeal/ Lawsuit

PUT-012316.99/2019/PP/M.IIIA Of 2020 – 21 October 2020

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Strategies to Overturn Transfer Pricing Adjustments: Why the Tax Court Overruled the Tax Office's Reclassification of Promotional Expenses?

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-009605.15/2023/PP/M.IB Of 2025 – 19 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Victory at Tax Court! PT KAM Proves Interest-Free Loans Are Not Subject to Income Tax Article 23 Despite Related Party Status

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | Fully Granted

PUT-010298.12/2023/PP/M.IIIA Of 2025 – 15 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

From Audit Defeat to Court Victory: PT JSSI’s Strategy in Overturning a IDR 36 Billion Transfer Pricing Adjustment

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-000474.15/2024/PP/M.XIIIB Of 2025 – 20 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting

Winning Tax Appeals: Defending Against Constructive Dividend Allegations in Cross-Border Transfer Pricing Disputes

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | Fully Granted

PUT-000481.13/2024/PP/M.XIIIB Of 2025 – 20 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Reimbursement or Management Services? Key Success Factors of PT AN in Winning an Income Tax Article 23 Dispute at the Tax Court 

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | Fully Granted

PUT-012318.12/2023/PP/M.XB Of 2025 – 26 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning on Procedure: Billions of Rupiah in Tax Corrections Failed Due to This Negligence by the DJP

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-013299.15/2019/PP/M.IIIA Of 2020 – 22 October 2020

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Transfer Pricing Appeals: Challenging the Validity of DJP Comparable Data

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-001912.15/2023/PP/M.XVIB Of 2025 – 22 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Even Judges Make Calculation Errors! How PT AJ Successfully Secured a Decision Revision at the Tax Court

Tax Court Decision | Annual Corporate Income Tax | Appeal | To Amend

PUTP1-001481.15-2024/PP/R1/MXVIIIB Of 2025 – 5 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

A Typo Leading to Supreme Court Rejection: The Critical Importance of Administrative Precision in Tax Rulings

Tax Court Decision | Annual Corporate Income Tax | Appeal | To Amend

PUTP1-007267.15/2022/PP/M.XVIA Of 2025 – 27 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

From Typo to Court: How PT RI Corrected Billion-Rupiah Figures in a Tax Decision

Tax Court Decision | PPN | Appeal | To Amend

PUTP2-000521.16/2024/PP/M.IXA Of 2025 – 3 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning a VAT Dispute: Why Compensation Discounts Can Still Reduce the Tax Base? 

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-001530.16/2024/PP/M.VB Of 2025 – 2 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Plantation Tax Dilemma: Mandatory Employee Facilities with Non-Creditable Input Tax? 

Tax Court Decision | PPN | Appeal | To Reject the Appeal/ Lawsuit

PUT-001609.16/2023/PP/M.XVIIIA Of 2025 – 10 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Strategies for Addressing Constructive Dividend Adjustments: Lessons from the PT SUR Income Tax Article 26 Case

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Partially Granted

PUT-003117.13/2024/PP/M.IA Of 2025 – 12 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Victory at Tax Court: Material Substance of Tax Payment Prevails Over Rigid Procedural Rules

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-003862.16/2024/PP/M.IVA Of 2025 – 27 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

VAT Lawsuit Victory! Judges Annul JO Correction Despite Incorrect Tax Invoice Codes

Tax Court Decision | Tax Lawsuit | Lawsuit | Fully Granted

PUT-003904.99/2024/PP/M.XVIB Of 2025 – 5 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Wins Against Multi-Million Dollar Tax Correction: Tax Court Rejects DJP's Assumption and Acknowledges Technical Service Fee as Essential Production Cost

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-001759.15/2024/PP/M.VB Of 2025 – 19 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Are Domestic Related-Party Transactions Safe from VAT Correction? Lessons from the PT FMI Case

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-004995.16/2024/PP/M.IXB Of 2025 – 11 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning Tax Disputes: Lessons from the PT TBSM Case on Goods Flow Documentation

Tax Court Decision | Annual Corporate Income Tax | Appeal | Partially Granted

PUT-007128.15/2024/PP/M.XIVB Of 2025 – 15 May 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Profit Decline During Pandemic, Affiliate Service Costs Remained Deductible: A Landmark Victory for PT SMI

Tax Court Decision | Annual Corporate Income Tax | Appeal | Fully Granted

PUT-007656.15/2023/PP/M.IIIB Of 2025 – 3 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Claiming Restitution Rights: Important Lessons from PT ILI's Legal Actions in the Corporate Income Tax Overpayment Dispute

Tax Court Decision | Annual Corporate Income Tax | Lawsuit | To Reject the Appeal/ Lawsuit

PUT-001850.99/2018/PP/M.IIIA Of 2019 – 29 January 2019

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning the Appeal: Why DJP Portal Data Alone is Insufficient for Tax Corrections? 

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-008490.16/2021/PP/M.VIA Tahun 2025 – 3 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Decisively Prevails Over Account Receivable Testing: Lessons from the PT MSA Case

Tax Court Decision | PPN | Appeal | Partially Granted

PUT-008674.16/2020/PP/M.XVB Of 2024 – 18 December 2024

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Does Misinputting a Counterparty's Name Lead to Billions in Underpayment Assessments? Observe TLI's Victory in Tax Court 

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Fully Granted

PUT-009900.13/2020/PP/M.XA Of 2025 – 12 June 2025

Decision
April 01, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Validity of Foreign Service VAT Crediting in Intra-Group Cost Sharing Schemes

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-010815.16/2023/PP/M.IIIB Of 2025 – 3 June 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Double Jeopardy: Why a Taxpayer Lost in Income Tax But Won in VAT Even When Royalty Was Declared Zero?

Tax Court Decision | PPN | Appeal | To Reject the Appeal/ Lawsuit

PUT-000828.17/2020/PP/M.XIA Of 2024 – 11 November 2024

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Protecting VAT Facility in Bonded Warehouse: Judges Cancel DJP’s Correction Because of This Certain Mistake

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-001303.16/2019/PP/M.IIIA Of 2020 – 30 July 2020

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Fate of Genset vs. Fertilizer Input VAT: A Case Study on VAT Crediting During the Pre-Operational Phase of the Palm Oil Sector

Tax Court Decision | PPN | Appeal | Partially Granted

PUT-001709.16/2018/PP/M.VIIIA Of 2019 – 29 July 2019

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Battle of Service Classification vs. Deemed Dividend: Tax Court Annuls WHT Article 26 Due to Intra-Group Service Cost Correction

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Fully Granted

PUT-014505.13/2022/PP/M.XIIA Of 2025 – 19 Mei 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Trapped in Formality: Tax Court Rejects Lawsuit for Return of Tax Assessment Cancellation Request over This Simple Mistake

Tax Court Decision | Lawsuit | To Reject the Appeal/ Lawsuit

PUT-012245.99/2023/PP/M.XIVA Tahun 2025 – 4 Juni 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Winning in Tax Court: When the DJP's Average Price Comparison Method Was Rejected Due to This Reason

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-002182.16/2024/PP/M.XIVA Of 2025 – 22 May 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayers' Ultimate Strategy: Winning Corporate Income Tax Appeal Against IDR 1.7 Billion Turnover Correction Due to This Mistake by the DJP

Tax Court Decision | PPN | Appeal | Fully Granted

PUT-002125.15/2024/PP/M.XIVA Of 2025 – 22 May 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Wins Total Victory: Service Payments to Non-Shareholder Affiliates Fail to Be Corrected as Disguised Dividend Under CIT Article 26

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Fully Granted

PUT-004142.13/2021/PP/M.XB Tahun 2025 – 28 July 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Accrued Salary Expense Rejected by Tax Judge: DJP's Key to Victory in Article 21 Withholding Tax Dispute

Tax Court Decision | Income Tax Article 21 (Non-Final) | Appeal | To Reject the Appeal/ Lawsuit

PUT-012712.10/2023/PP/M.XIIB Of 2025 – 30 July 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Wins Against Article 26 Withholding Tax Correction on Deemed Interest: GMS Evidence Overrules Debt Accounting Classification in Affiliate Transactions

Tax Court Decision | Income Tax Articles 23/26 (Final) | Appeal | Fully Granted

PUT-008541.13/2023/PP/M.XIIA Of 2025 – 30 June 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Loss on Receivables Assignment to Affiliates Not Recognized as MEE Expenses: Key Lessons from PT CEPA’s Case

Tax Court Decision | Annual Corporate Income Tax | Appeal | To Reject the Appeal/ Lawsuit

PUT-013825.15/2022/PP/M.XIIA Of 2025 – 30 June 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The "Effectively Connected" Trap: When Head Office Loan Interest is Deemed PE Income Subject to Corporate Income Tax

Tax Court Decision | Annual Corporate Income Tax | Appeal | To Reject the Appeal/ Lawsuit

PUT-012493.15/2023/PP/M.XIIB Of 2025 – 31 May 2025

Decision
March 31, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Warning! Representative Office of a PE Must Still Pay Branch Profit Tax If Actively Involved in This Transactions

Tax Court Decision | Income Tax Article 26 (Non-Final) | Appeal | Fully Granted

PUT-012491.13/2023/PP/M.XIIB Of 2025 – 4 June 2025

Decision
January 14, 2026 • Taxindo Prime Consulting | Dita Rahmah Fitri - Lilik F Pracaya, Ak., CA., ME., BKP (C)

When Employee Benefits Are Not Automatically Subject to Income Tax Article 21

Tax Court Decision | Income Tax Article 21 (Non-Final) | Appeal | Fully Granted

PUT-006540.102023PPM.XIIIA Year 2025 - Agustus 21, 2025

Decision
January 14, 2026 • Taxindo Prime Consulting | Dita Rahmah Fitri - Lilik F Pracaya, Ak., CA., ME., BKP (C)

From Market Support to Core Business: Where Did BUT Begin?

Tax Court Decision | Income Tax Article 15 (Final) Appeal | Fully Granted

PUT-010233.272024PPM.XA Year 2025 - August 28, 2025

Decision
January 14, 2026 • Taxindo Prime Consulting | Dandy Adams - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Implications of Applying Article 23 Paragraph (4) Letter H of the Income Tax Law in a Dispute Over Tax Withholding on Factoring Interest Paid to a Financing Company

Tax Court Decision | Income Tax Article 23 (Non-Final) Appeal | Fully Granted

PUT-006705.12/2024/PP/M.XIB September 25, 2025

Decision
January 14, 2026 • Taxindo Prime Consulting | Dandy Adams - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Unveiling the Fair Value of Family Shares: The Story of a Rp15 Billion Tax Dispute Behind the Transfer of PT TBS Shares

PUT-010844.14/2022/PP/M.XXB September 14th, 2023

Decision
January 14, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayers' Ultimate Strategy: Winning Corporate Income Tax Appeal Against IDR 1.7 Billion Turnover Correction Due to This Mistake by the DJP

PUT-002125.15/2024/PP/M.XIVA Of 2025 – 22 May 2025

Decision
January 14, 2026 • Taxindo Prime Consulting | Dandy Adams - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Failure of Proof Through Sampling: Reviewing the Appeal Loss of PT AALI's Article 23 Income Tax Over VAT Data Equalization

PUT-010779.12/2019/PP/M.XVIIIB September 25, 2025

Decision
January 14, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

DJP's Business Valuation Fails to Correct Hundreds of Billions in Corporate Income Tax in PT SP’s Debt-to-Equity Swap Case

PUT-009753.15/2024/PP/M.IXA Of 2025 - 30 September 2025

Decision
January 14, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Public Accountant’s Error Causes IDR 20 Billion Tax Correction: The Key to a Taxpayer’s Victory Against Assumptive Cash Flow Testing

PUT-005099.15/2021/PP/M.IVB Of 2025 - 25 September 2025

Decision
January 12, 2026 • Taxindo Prime Consulting - Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxpayer Claims Wages Below PTKP, Appeal Rejected: Tax Court Affirms New Evidence is Inadmissible Post-Examination!

PUT-005499.10/2024/PP/M.XIVB Of 2025, 26 August 2025

Decision
January 12, 2026 • Taxindo Prime Consulting | Irfan Gunawan, S.Ak, BKP., CTT., CPTT. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Triumph of Justice at the Tax Court: PTAB Successfully Nullifies VAT Administrative Sanctions
 

PUT-000664.99/2025/PP/M.IXA – July 29, 2025

Decision
January 12, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The PPh Article 23 Trap! Service Costs Recognized in Financial Statements, But Withholding Tax Forgotten: Here's the Consequence at the Tax Court

PUT-013097.12/2021/PP/M.VIIIB Of 2025 - 13 August 2025

Decision
January 12, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Fighting the Salary Equalization Trap: PT AT Indonesia’s Strategy to Annul the Majority of PPh Article 21 Corrections at the Tax Court

PUT-010449.10/2023/PP/M.XIIIB Of 2025 - 26 August 2025

Decision
January 12, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Beware! Failure to Segregate Services and Goods, Multi-Billion WHT 23 Correction Confirmed, Only a Small Portion Granted by the Tax Court

PUT-011389.12/2019/PP/M.XVIIIB Of 2025, 30 September 2025

Decision
January 12, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Tax Assessment Letter Worth Billions Completely Cancelled! Key to Taxpayer Victory in Forestry Sector: Production Volume is Not Proof of Sales

PUT-001987.15/2024/PP/M.IIIA Of 2025 - 2 October 2025

Decision
January 12, 2026 • Taxindo Prime Consulting | Dita Rahmah Fitri - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Severance Pay, Leave Compensation, and Final Article 21 Income Tax: What the Tax Authority Often Gets Wrong

PUT-007355.28/2022/PP/M.VIIIA (2025) - 6 October 2025

Decision
January 12, 2026 • Taxindo Prime Consulting | Dandy Adams - Lilik F Pracaya, Ak., CA., ME., BKP (C)

The Importance of Article 23 Income Tax Exemptions: Analysis of a Tax Court Ruling on Financial Services and Shipping Services.

PUT-006706.12/2024/PP/M.XIB September 25, 2025

Decision
January 08, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H

The Formal Trap in Tax Rulings: When a Single Spelling Error Thwarts a Taxpayer's Right to Judicial Review

PUTP1-058385.10/2008/PP/M.XIIIB Of 2025 - 19 August 2025

Decision
January 08, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H

Taxpayer's Legal Trap: Why VAT Penalty Abatement Requests Must be Challenged as a Lawsuit, Not an Appeal?

PUT-004739.16/2023/PP/M.XXB Of 2025 - 21 August 2025

Decision
January 08, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H

Warning! Payments for Group Services Can Turn into Dividends Subject to WHT Art. 26

PUT-001564.13/2024/PP/M.XIIIA Of 2025 - 28 August 2025

Decision
January 08, 2026 • Taxindo Prime Consulting | Adv. Muhammad Faiz Nur Abshar, S.H

Oil and Gas PE Profit Tax Rate: DTA Utterly Defeated in the Tax Court! Analysis of the Decision that Prioritizes the PSC for State Revenue Assurance

PUT-007610.36/2023/PP/M.XIA Of 2025 - 28 August 2025

Decision
January 06, 2026 • Taxindo Prime Consulting

Reconstruction of Legal Certainty in Tax Restitution: Analysis of Decision PUT-000254.99/2022/PP/M.VIB of 2024

PUT-000254.99/2022/PP/M.VIB of 2024 - December 19, 2024

Decision
January 06, 2026 • Taxindo Prime Consulting

Taxpayers Must Know! If the Tax Court Decision Date is Wrong, Here is How to Correct it Through a Correction Lawsuit

PUTP1-007214.99/2024/PP/M.XIB Of 2025 - 20 August 2025

Decision
January 06, 2026 • Taxindo Prime Consulting - Adv. Muhammad Faiz Nur Abshar, S.H.

Saved from PMK 18/2021 Correction! The Key to Success for Industrial Forest PKP in Passing the 5-Year "Has Produced" Check

PUT-002416.16/2024/PP/M.XIIA Of 2025 - 25 August 2025

Decision
January 04, 2026 • Taxindo Prime Consulting - Dita Rahmah Fitri

When Sales Discounts Are Considered Income

PUT-002771.122024PPM.XVIA Year 2025 — 27 Februari 2025

Decision
January 04, 2026 • Taxindo Prime Consulting - Adv. Muhammad Faiz Nur Abshar, S.H.

Foreign Service VAT on Salary Reimbursement Denied! Crucial Lesson: Expatriate Salary Transfer Proof is Stronger Than NTPN-Validated Payment Slips

PUT-014740.16/2020/PP/M.XIA Of 2025 - 25 September 2025

Decision
January 04, 2026 • Taxindo Prime Consulting - Dandy Adams

Resounding Victory! Logistics Company Avoids Hundreds of Millions in Tax Bill Due to Difference in Interpretation of Ship Charter and Outright Sale

PUT-006687.27/2024/PP/M.XIB Year 2025 - September 25, 2025

Decision
January 04, 2026 • Taxindo Prime Consulting - Dita Rahmah Fitri

Affiliate Price Adjustments Not Recognized as Basis for PPh 22 Import Collection

PUT-000666.112022PPM.XB Year 2025 Date May 27, 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

The Input VAT Direct Use Trap: Hundreds of Billions in Advertising Costs Forfeited for Lack of Connection to Core Product

PUT-010155.16/2023/PP/M.XIIB Of 2025 - 18 June 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

Tax Court Cancels Rp18.7 Billion Correction on Land Swap Transaction of PT ML

PUT-000858.25/2024/PP/M.VIB Tahun 2025 - June 13, 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

A Decisive Win! Taxpayer Defeats VAT Correction on Management Fees Without Flight Tickets or Hotel Evidence

PUT-011658.16/2019/PP/M.IIB Of 2025 - 29 Agustus 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

Stumbling on a Courtroom Admission: IDR 4.2 Million WHT Article 23 Correction Upheld Despite Claims of Procedural Flaw

PUT-005437.12/2024/PP/M.VA Of 2025 - 22 September 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

Administrative Blunder Risks IDR 4 Billion! See How the Taxpayer Won the Head Office vs. Branch VAT Battle

PUT-010373.16/2024/PP/M.IIB Of 2025 - 18 September 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

Absolute Victory! PT TIS Refutes DJP’s VAT Equalization Correction with This Evidence

PUT-012130.12/2023/PP/M.XIVA Of 2025 - 10 September 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

DJP's WHT Article 23 Correction Nullified! The Key Lesson: Accounting Equalization is Not Concrete Legal Evidence

PUT-014747.12/2020/PP/M.XIA Of 2025 - 25 September 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

Wiped Out or Recognized? The Fate of IDR 105 Billion Loss Compensation Determined by Prior Year Dispute Rulings

PUT-011905.15/2023/PP/M.IVB Of 2025 - 19 June 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

Substance Over Formality: PT DR Wins Victory in KSO VAT Dispute

PUT-004063.99/2024/PP/M.XVIB Year 2025 - June 5, 2025

Decision
December 28, 2025 • Taxindo Prime Consulting

Finding Fair Value: Tax Court Partially Grants PT IMS's Appeal, Reduces Property Transaction Value by IDR 24.2 Billion.

PUT-004731.25/2023/PP/M.IIB 2025 - September 9, 2025.

Decision
December 28, 2025 • Taxindo Prime Consulting

Non-Commercial Value Exports Must Still Be Declared in the VAT Return: Key Lesson from PT FEIN’s Dispute with the DJP

PUT-003462.16/2022/PP/M.IA Of 2025 - 17 September 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Legal Certainty Guaranteed! Tax Court Overturns DGT's Rejection of FPU Asset Benefit Period for PT TOI

PUT-006379.99/2024/PP/M.IVB Year 2025 - May 15, 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Assessing the Fair Value of Affiliated Assets: Fiscal Assessment Correction Council on Final Income Tax on Property

PUT-009471.252022PPM.XIIB Year 2025 - May 14, 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

The Defeat of a Soft Drink Giant: Why Was IDR 250 Billion in Promotional Expenses Rejected by the Tax Court?

PUT-010143.15/2023/PP/M.XIIB Of 2025 - 18 June 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Correction Upheld: Amendments to Tax Returns During a Tax Audit Do Not Change the PP 46/2013 Tax Regime

PUT-011617.15/2022/PP/M.XIII.A Year 2025 – 22 May 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Limits of the Examination of the Matching Cost Principle in the CML Dispute

PUT-002859.15/2023/PP/M.XIIA Year 2025 – 28 April 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Tax Case Study: The Importance of Formal Requirements and the Enforcement Power of Tax Collection

PUT-001567.99/2022/PP/M.IVB Year 2025 - September 25, 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

VAT Dispute Won! Unloading Bailout Costs Are Not Taxable Objects, Here's Why

PUT-004838.16/2024/PP/M.VIA Of 2025, 30 September 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Failure to Carefully Determine the Date, DGT Forced to Cancel SKPN PPN: Tax Court Decision Affirms Principle of Legal Certainty for Taxpayers

PUT-001840.99/2025/PP/M.IXA Year 2025 - September 2, 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Partial Victory for PT TLI: PPh Article 21 as COGS in Manpower Service Businesses

PUT-000759.15/2020/PP/M.XA Year 2025 – 12 June 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Crushing Defeat Due to Wrong Comparables Selection: Tax Court Revokes PT SMS's IDR 42 Billion Affiliated Rent Correction

PUT-005312.15/2024/PP/M.XIA Of 2025 - 21 July 2025

Decision
December 25, 2025 • Taxindo Prime Consulting

Taxpayers Must Know! One Formal Error Can Cause Your SKP Cancellation Request to Be Absolutely Rejected by the DGT

PUT-008269.99/2024/PP/M.IIIA Year 2025 - September 11, 2025

Decision
December 20, 2025 • Taxindo Prime Consulting

Rig's Legs Are Not Permanent, Final Tax Cancelled: The Legal Boundaries of Construction Services PPh in a Trillion Rupiah Dispute

PUT-002030.25/2023/PP/M.VIIIA Of 2025 - 22 September 2025

Decision
December 20, 2025 • Taxindo Prime Consulting

Paid VAT on Foreign Services, But Got Corrected? Beware of Recharacterization of Affiliate Services as Disguised Dividends!

PUT-012913.16/2020/PP/M.IIA Of 2025 - 19 September 2025

Decision
December 20, 2025 • Taxindo Prime Consulting

Legal Certainty at the End of Discretion: Why the Tax Court Completely Overturned the DGT's Decision on PT PC

PUT-011945.99/2023/PP/M.XVIB Year 2025 - May 22, 2025

Decision
December 20, 2025 • Taxindo Prime Consulting

The Cash Flow Trap: When Bank Loans Are Treated as Revenue by Tax Authorities

PUT-003021.16/2024/PP/M.XA Of 2025 - 24 September 2025

Decision
December 20, 2025 • Taxindo Prime Consulting

Final PPh vs PPh Article 23: Cold Storage Wins Against DJP Correction, Annuling Withholding Tax Obligation!

PUT-006706.12/2024/PP/M.XIB Of 2025 - 25 September 2025

Decision
December 20, 2025 • Taxindo Prime Consulting

VAT Appeal Rejected Due to This Simple Mistake! A Valuable Lesson for Taxpayers from the Case of PT PGL

PUT-006692.16/2024/PP/M.XIB Of 2025 - 25 September 2025

Decision
December 20, 2025 • Taxindo Prime Consulting

The 3-Month Deadline as Key to Tax Finality: Why PT AKJ's Lawsuit Was Rejected After Attempting to Re-Challenge the Same SKP

PUT-009747.99/2024/PP/M.XIVA Of 2025 - 23 July 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

Cancelled Payment of Rp 5.6 Billion: PT IP's Victory in Constructive Dividend Dispute

PUT-009432.12/2024/PP/M.IB - 21 Juli 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

Tax Assessment Annulled! Tax Court Reveals DJP’s Fatal Flaw: Why Merging 12 Tax Periods Became a Boomerang?

PUT-012130.12/2023/PP/M.XIVA Of 2025 - 13 August 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

Absolute Victory: PT LTI Overturns CIT Corrections on COGS and Fiscal Loss Compensation

PUT-001505.15/2021/PP/M.XB Year 2025 – June 23, 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

Warning: A Paid VAT-FTS Payment Slip Can Be Non-Creditable! Case Study on Affiliated Manpower Costs from Korea

PUT-014738.16/2020/PP/M.XIA Of 2025, 25 September 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

The 'Magical' Expat Salaries in Klaten: The Story of a Garment Company Challenging DJP's Fictitious Salary Standards

PUT-006519.10/2018/PP/M.IIB Year 2019 - June 20, 2019

Decision
December 15, 2025 • Taxindo Prime Consulting

Discount or Reward? The Story of PT TV vs. DJP in the Tax Court

UT-005043.12/2021/PP/M.IIB - June 12th, 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

VAT on Management Fee Paid a Year Late: Tax Court Rejects PT FI's Appeal Due to Incorrect Tax Period on BPN

PUT-003525.16/2024/PP/M.XVA Of 2025, 8 September 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

Unraveling the Misinterpretation of Deemed Interest A Tax Court Decision that Reinforces the Burden of Proof

PUT-009197.122023PPM.XIIIA Year 2025 - September 25, 2025

Decision
December 15, 2025 • Taxindo Prime Consulting

Taxpayer's Lawsuit Granted: Failing to Attach DGT-2 Is Not a Sole Basis for PPh Article 26 Tax Collection Letter Issuance

PUT-004841.99/2018/PP.MIVA Dated March, 19 2019

Decision
December 15, 2025 • Taxindo Prime Consulting

Crucial Victory for PT AGN: FPSO Classified as Tangible Asset Group III, Cancels Rp99 Billion Correction

PUT-001367.15/2023/PP/M.VIIIB Year 2025 – June 25, 2025

Decision
December 14, 2025 • Taxindo Prime Consulting

Lawsuit Granted! When a Taxpayers Objection is Flatly Rejected for an Erroneous Administrative Reason

PUT-008772.99/2018/PP/M.IIB Of 2019 - 1 August 2019

Decision
December 14, 2025 • Taxindo Prime Consulting

DJP Denies Interest Refund, Taxpayer Fights Back via Article 36 of UU KUP Path and Wins in Tax Court

PUT-004752.99/2018/PP/M.XXB Of 2019 - 14 March 2019

Decision
December 14, 2025 • Taxindo Prime Consulting

Turning Point in Corporate Income Tax Disputes: Panel Affirms Expenses are Still Deductible Even If Tax Hasn't Been Withheld?

PUT-002035.15/2024/PP/M.IIIA Tahun 2025 – July 17, 2025

Decision
December 08, 2025 • Taxindo Prime Consulting

Signature Stamps Cannot Preclude the Right to Object: Important Lessons from PT YMEI's Victory in Tax Court

PUT-008772.99/2018/PP/M.IIB Year 2019 - August 1, 2019

Decision
December 04, 2025 • Taxindo Prime Consulting

Wrong Legal Path Chosen: PT ASD's Tax Assessment Cancellation Request Flatly Rejected for 'Double Dipping' and Invalid Power of Attorney

PUT-008268.99/2024/PP/M.IIA Of 2025, 11 September 2025

Decision
December 04, 2025 • Taxindo Prime Consulting

Taxpayer’s Strategy to Overcome Most of the DJP's Corrections to Article 26 Income Tax Disputes Based on Foreign VAT Data

PUT-002219.13/2020/PP/M.IIIA Of 2022 - 30 June 2022

Decision
December 04, 2025 • Taxindo Prime Consulting

Strong Transfer Pricing Evidence Overturns PPh Article 26 Correction: Why the DJP's Secondary Adjustment Claim Failed at the Tax Court

PUT-002207.13/2024/PP/M.VIIIA Of 2025 - 27 August 2025

Decision
December 02, 2025 • Taxindo Prime Consulting

Winning an Appeal Due to Different Dates: Tax Court Decision Annuls PT AAC's Rp. 1.4 Billion Final Income Tax SKPKB

PUT-010879.25/2023/PP/M.IIB Of 2025 - 12 August 2025

Decision
December 02, 2025 • Taxindo Prime Consulting

A Landmark Offshore Industry Ruling: Reassessing Final Income Tax on Rig Manufacturing

PUT-002030.252023PPM.VIIIA Year 2025 —Dated 22 September 2025

Decision
December 02, 2025 • Taxindo Prime Consulting

Receivables-to-Equity IPO: PT PM Secures Total Victory Against Fair Value Adjustments

PUT-003663.15/2023/PP/M.XIB Tahun 2025 - August 6, 2025

Decision
December 02, 2025 • Taxindo Prime Consulting

Forex Loss on Holding Company Bonds Deemed Non-Deductible: PT IMS Ruling Affirms the Cost-Matching Principle

PUT-006496.15/2021/PP/M.XIIA Year 2024 - October 21, 2024

Decision
December 01, 2025 • Taxindo Prime Consulting

The Legal Construction of Involuntary Settlement in the Cancellation of Tax Administrative Sanctions: A Case Study of PT IRS

PUT-000218.99/2018/PP/M.VIIIB - 27 February 2019

Decision
December 01, 2025 • Taxindo Prime Consulting

Correction of Income Tax Article 23 on Plasma Impairment Declared Inappropriate by the Tax Court

PUT-007710.122023PPM.XIIB Year 2025 - February 26, 2025

Decision
December 01, 2025 • Taxindo Prime Consulting

Court Ruling Excerpt: Ordinary Discount or Tax Object?

PUT-006248.12/2024/PP/M.XIVA 2025 - September 17, 2025

Decision
December 01, 2025 • Taxindo Prime Consulting

Cash Flow Test and Vague Positum: PT SNS Secures Partial Victory in Legal Evidence Dispute!

PUT-004865.15/2023/PP/M.XXB Tahun 2025 - July 10, 2025

Decision
November 30, 2025 • Taxindo Prime Consulting

Jurisprudential Implications of PMK 8/2013: Collection Penalties under KUP Article 27 (5d) Cannot be Waived via Administrative Petition.

PUT-011706.99/2023/PP/M.XB Year 2025 dated July 21, 2025

Decision
November 30, 2025 • Taxindo Prime Consulting

Huge VAT Correction Annulled! The KPBN vs. Bappebti Data Showdown in a CPO Transfer Pricing Dispute

PUT-007008.16/2024/PP/M.XVIIIB Of 2025, 24 July 2025

Decision
November 30, 2025 • Taxindo Prime Consulting

Administrative Requirements for Writing Off Receivables Were Missed During SPT Submission? What Was the Outcome?

PUT-004064.15/2024/PP/M.XXB Tahun 2025 – June 19, 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

Quality Claims and In-Kind Benefits Challenged: PT TMP Secures Partial Victory in Corporate Income Tax Dispute

PUT-002832.15/2021/PP/M.XVIIIA, June 10, 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

The Tax Court Panel of Judges Cancels Rp51.8 Billion Correction: External CUP Analysis of SICOM & Loan Interest Considered Reasonable

PUT-008420.15/2023/PP/M.XXB Tahun 2025 – 7 Agustus 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

Royalty Payment of IDR 10.7 Billion Rejected! No Proof of Know-How

PUT-004152.15/2024/PP/M.IA Year 2025 – 18 June 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

Palm Oil Plasma Scheme Partnership Wins at the Tax Court: When Cost Corrections are Reversed into Business Revenue

PUT-005461.15/2024/PP/M.XIVB Of 2025, 25 August 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

Taxpayer Wins: The 2.51% Margin is 'Arm's Length', Tax Office Barred from Adjustment

PUT-002636.15/2023/PP/Μ.ΧΑ Of 2025, 27 August 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

Royalty Payments to Affiliates Still Corrected! The Two Key Lessons from This Tax Court Ruling

PUT-006760.15/2020/PP/M. XVIB Of 2025, 14 August 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

Defeated at the Tax Court: A key lesson for Taxpayers in a VAT Dispute

PUT-005473.16/2024/PP/M.XIVB Of 2025, 26 August 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

Taxpayer Administrative Justice: Tax Court Cancels DGT Letter that “Delays” Administrative Process

PUT-003001.99/2024/PP/M.XVA Year 2025 - September 8, 2025

Decision
November 29, 2025 • Taxindo Prime Consulting

VAT and PPh 23 Reported in Different Months: PT HKR Wins VAT DPP Correction Appeal at the Tax Court

PUT-002225.16/2023/PP/M.XVIIIA Of 2025, - 26 August 2025

Decision
November 28, 2025 • Taxindo Prime Consulting

Implications of Timing Differences in Recognition of Advance Payments and Delivery of Goods on Corrections to the VAT Tax Base

PUT-010985.16/2020/PP/M.XB Year 2025 - August 4, 2025

Decision
November 27, 2025 • Taxindo Prime Consulting

The Importance of PBK: A Real Case Study of Unrecognised Tax Credits

PUT-003031.112024PPM.VIA Year 2025 - June 03, 2025

Decision
November 25, 2025 • Taxindo Prime Consulting

Dispute Regarding Proof of Fixed Asset Write-off Without Official Record; Final Outcome Remains VAT Not Payable

PUT-000208.16/2024/PP/M.IIIA of 2025, - August 28, 2025

Decision
November 25, 2025 • Taxindo Prime Consulting

Implications of Burden of Proof: Tax Court Rejects Tax Base Correction Based Solely on Raw Material Flow Testing

PUT-015393.16/2020/PP/M.IVB Year 2025 Dated August 12, 2025

Decision
November 25, 2025 • Taxindo Prime Consulting

Rejected! PT KPC's ‘Mistake’ Argument in P3B Fails in Tax Court

PUT-010573.99/2023/PP/M.XXB Year 2025 - July 3, 2025

Decision
November 24, 2025 • Taxindo Prime Consulting

Unraveling the Polemic of Kenaf Purchases: Questionable PPh 22 Collection

PUT-003485.112024PPM.IA Year 2025 - June 12, 2025

Decision
November 24, 2025 • Taxindo Prime Consulting

Hidden Dividend or Real Service? The Intriguing Story Behind PT AAC's Victory at the Tax Court 

PUT-010850.12/2023/PP/M.IIIB January 7, 2025

Decision
November 24, 2025 • Taxindo Prime Consulting

HGU Documents Are Not Always Proof: This Ruling Voids Rp12.7 Billion Non-Operating Income Correction!

PUT-011495.15/2023/PP/M.IIIA Year 2025 – June 12, 2025

Decision
November 24, 2025 • Taxindo Prime Consulting

Freight Income Exports of BKP are not objects of 10% VAT. Exports of JKP are consequences of the Destination Principle

PUT-009273.16/2023/PP/M.IIB Year 2025 - August 7, 2025

Decision
November 24, 2025 • Taxindo Prime Consulting

Shareholder Debt During Liquidation Considered Profit? Tax Court Annuls a Rp. 10 Billion Correction

PUT-012038.15/2023/PP/M.ΧΙΙΙΑ Of 2025 - 28 August 2025

Decision
November 21, 2025 • Taxindo Prime Consulting

The Concrete Data Trap: Why a Bank Credit Audit Report Triggered a 200% Tax Amnesty Penalty?

PUT-010656.77/2020/PP/M.XIB Of 2025 - 3 September 2025

Decision
November 21, 2025 • Taxindo Prime Consulting

When Asset Sales Are Treated as Business Transfers: PT CMAP Escapes Major Tax Adjustment at the Tax Court

PUT-014399.15/2022/PP/M.VIIIA Tahun 2025 - 30 Juni 2025

Decision
November 19, 2025 • Taxindo Prime Consulting

Proven Duplication of Intra-Group Services: The Tax Court Panel of Judges Upholds DGT's $8.9 Billion Correction

PUT-001563.15/2024/PP/M.XIIIA YEAR 2025 – 28 AUGUST 2025

Decision
November 19, 2025 • Taxindo Prime Consulting

Can Accounts Receivable Flow Testing Be Used as a Basis for Tax Adjustments? The PT SI Decision Provides the Answer!

PUT-108743.15/2013/PR/M.XIIIB Year 2019 – 26 February 2019

Decision
November 19, 2025 • Taxindo Prime Consulting

NPWP Branch vs. NPWP Head Office Dispute: The Story of PT BB's Final Income Tax PPh

PUT-003791.27/2022/PP/M.XVIB TAhun 2025 - 31 Juli 2025

Decision
November 19, 2025 • Taxindo Prime Consulting

Difference in Accounting vs. Tax Interpretation: Court Exempts Taxpayer from Fictitious Article 23 Income Tax

PUT-011203.12/2023/PP/M.XVIB Tahun 2025 - 21 Agustus 2025

Decision
November 18, 2025 • Taxindo Prime Consulting

Beware! DGT's Accounts Receivable Flow Test Can Trigger Rp5.7 Billion Correction—Here's PT SAI's Key Defense!

PUT-008679.15/2021/PP/M.IVA Year 2025 – June 10, 2025

Decision
November 18, 2025 • Taxindo Prime Consulting

The Tax Court Panel of Judges Annuls IDR 4.6 Billion Adjustment:
TNMM Ruled the Most Appropriate Method for Toll Manufacturers

PUT-002636.15/2023/PP.M.XA (2025) - 27 August 2025

Decision
November 16, 2025 • Taxindo Prime Consulting

Tax Court Annuls Input VAT Corrections on Non-Reporting Counterparties and Cleaning Service Fees

PUT-003603.16.2024.PPM.IB Of 2025 - 21 July 2025

Decision
November 14, 2025 • Taxindo Prime Consulting

Year-End Bonus Adjustment under Article 21 Income Tax: Dispute on Accrual versus Actual Payment Recognition

PUT-003390.10/2024/PP/M.XVA Year 2025 - August 4, 2025

Decision
November 14, 2025 • Taxindo Prime Consulting

Failure to Prove Raw Material Status: VAT on Imported Fish Feed Annulled, Strategic Facility Upheld

PUT-004394.47/2018/PP/M.XVIIA Of 2019 - 15 May 2019

Decision
November 14, 2025 • Taxindo Prime Consulting

Foreign Representative Office Slapped with 100% VAT Penalty: The Harsh Lesson for Permanent Establishments with Zero Sales

PUT-005347.16/2018/PP/M.XXA Of 2019 - 13 August 2019

Decision
November 14, 2025 • Taxindo Prime Consulting

DGT Loses in Transfer Pricing Dispute - IDR 5.53 Billion Adjustment Canceled
The Tax Court Panel of Judges Finds CPKO Pricing Arm’s Length

PUT-005500.15/2024/PP/M.XIVB Year 2025 – August 26, 2025

Decision
November 14, 2025 • Taxindo Prime Consulting

Not About Farmers, Tax Court Rules IUP Legality is Key for Tin Withholding Agent

PUT-003722.11/2024/PP/M.IIIA Year 2025 - March 13, 2025

Decision
November 13, 2025 • Taxindo Prime Consulting

Purchase of FFB Through the Farmers' Cooperative Administrative Coordinator (for) Transactions Not Subject to PPh 22

PUT-009066.11/2021/PP/M.IIA Year 2025 - August 1, 2025

Decision
November 13, 2025 • Taxindo Prime Consulting

No Evidence of Management Services
The Tax Court Panel of Judges Maintains Correction of IDR 3 Billion!

PUT-009036.15/2024/PP/M.XVIB Year 2025 – 28 August 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

Taxpayer Substantiation Fails: Can a Screenshot Not Uphold the Claim?  

PUT-013088.15/2021/PP/M.VIIIB Tahun 2025 – August 13, 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

Correction of Input VAT for Foreign Management Services from Affiliated Party PT HWH Overturned by Tax Court

PUT-009275.16/2023/PP/M.IIB Tahun 2025 Tanggal 7 Agustus 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

When the Evidence Speaks: PT CSI Defeats the DGT's Correction on Business Turnover Equalisation

PUT-005037.152023PPM.XXB Year 2025 - August 14, 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

Losing the Proof, Winning Partially: PERUM B’s Crucial Lesson in PPh 22 Dispute Arising from VAT Data Discrepancy

PUT-004988.112021PPM.XVIIIA Of 2025 -12 August 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

DGT's Attempt to Shift Tested Party Fails Completely, PT AI's Appeal Granted

PUT-009630.15/2020/PP/M.VIIIA Of 2025 - 25 August 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

Reimbursement Costs Rejected by DJP but Accepted by the Tax Court: The Key to Proving Business Relevance

PUT-009275.16/2023/PP/M.IIB Of 2025 - August 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

Got a Bank Loan, but Passed It On to an Affiliate — What Does the DGT Say?

Tax Court Decision No. PUT-012794.15/2021/PP/M.IIA of 2025 – August 22, 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

Tax Court Validity of CUP and Multi-Year Data Amid Pandemic:
The DJP correction is valued at USD 532,624 and has been declared null

PUT- 004023.15/2024/PP/M.XIIA Year 2025 – August 11, 2025

Decision
November 11, 2025 • Taxindo Prime Consulting

Tax Court Rejects DJP's Selection of Comparable Companies Based on Profitability Size

PUT-002690.15/2024/PP.M.XVA – August 25, 2025

#"> The Tax Court granted the lawsuit against the rejection of the DJP's interest penalty waiver, as it was proven that PT ABI was not negligent<a href="#">#</a>
Decision
November 11, 2025 • Taxindo Prime Consulting
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The Tax Court granted the lawsuit against the rejection of the DJP's interest penalty waiver, as it was proven that PT ABI was not negligent#

PUT-000667.992025PPM.IXA Of 2025 - 20 July 2025

Decision
November 10, 2025 • Taxindo Prime Consulting

Reimbursement at Cost Does Not Constitute As VAT : Tax Court Cancels All DGT Corrections

PUT-002000.16/2024/PP/M.IIIB Year 2025 - August 19, 2025

Decision
November 10, 2025 • Taxindo Prime Consulting

Return Letter of Application for the Cancellation of Value Added Tax Assessment Letter Article 36 Paragraph (1) b Not Object of Lawsuit

PUT-005682.99/2021/PP/M.IIB Year 2025, - August 25, 2025

Decision
November 09, 2025 • Taxindo Prime Consulting

Equalization Is Not Final Proof: DGT Must Show Transaction Documents

No. PUT-010985.16/2020/PP/M.XB of 2025 - August 4, 2025

Decision
November 09, 2025 • Taxindo Prime Consulting

Appeal Against Income Tax Article 4 Paragraph (2) Rejected Due to Failure to Attend Trial Three Times

PUT-007243.25/2023/PP/M.VB - August 13, 2025

Decision
November 09, 2025 • Taxindo Prime Consulting

Umrah Services Subject to VAT? Check Out the Tax Court Decision Rejecting PT FWT’s Appeal!

PUT-001271.99/2024/PP/M.XVIA Year 2025 - Dated June 26, 2025

Decision
November 09, 2025 • Taxindo Prime Consulting

Affiliate Service VAT Reclassified as Dividend: How Taxpayers Overturned the DJP’s Secondary Adjustment at the Tax Court

PUT-006115.16/2023/PP/M.IIB Of 2025 - 10 July 2025

Decision
November 09, 2025 • Taxindo Prime Consulting

Doubtful Accounts Save Taxpayer from VAT Penalties: A Key Lesson from the Tax Court Decision

PUT-002817.16/2024/PP/M.VB Of 2025 - 25 June 2025

Decision
November 07, 2025 • Taxindo Prime Consulting

The Tax Court Panel of Judges Confirms: Interest-Free Loans Are Valid If the Company Is Proven to Be Loss-Making

PUT-005410.15/2024/PP.M.XIA Year 2025 – 24 July 2025

Decision
November 07, 2025 • Taxindo Prime Consulting

When Evidence Speaks Louder:
The Tax Court Panel of Judges Annuls USD 2,211,643 on Intra-Group Services

PUT-005445.15/2024/PP/M.IIIB Year 2025 – August 26, 2025

Decision
November 07, 2025 • Taxindo Prime Consulting

Automatic Tax Settlement Voids the Right to Appeal: The Case Study of PT TVS's VAT Penalty Waiver

PUT-002421.99/2019/PP/M.XIVB - November 20, 2019

Decision
November 06, 2025 • Taxindo Prime Consulting

Taxpayer Wins Partially at the Tax Court: The Crucial Lesson on Proving Cancellation of Tax Invoice 03 and VAT Deposit!

PUT-001768.16/2022/PP/M.XVlllA Of 2025 - 12 Agustus 2025

Decision
November 06, 2025 • Taxindo Prime Consulting

Article 21 Income Tax on Employee Early Retirement Payments Through a DPPK: Final Rate or Progressive Rate?

PUT-002187.10/2020/PP/M.IIIA - 23 Juni Tahun 2022

Decision
November 06, 2025 • Taxindo Prime Consulting

Negativa Non Sunt Probanda Principle: When the Tax Authority Cannot Shift the Burden of Proof 

PUT-010334.15/2023/PP/M.IA – August 22, 2025

Decision
November 06, 2025 • Taxindo Prime Consulting

Warning! Related-Party Service Expenses Disallowed by DJP Can Turn into Dividends Subject to PPh Article 26

PUT-009286.13/2023/PP/M.IIB Of 2025, 7 August 2025

Decision
November 05, 2025 • Taxindo Prime Consulting

A Win at the Tax Court Despite Lacking a Nominative List: Promotion Expenses Recognized as Long as Incurred for the 3M Principle

PUT-009897.15/2021/PP/M.XIA Of 2025 - 11 Agustus 2025

Decision
November 05, 2025 • Taxindo Prime Consulting

Not a Sale! Taxpayer Wins VAT Dispute After Proving Third-Party Stock Transfer is Not Taxable Supply of Goods (BKP)

PUT-007250.16/2023/PP/M.XIVA Of 2024 - 30 Oktober 2024

Decision
November 05, 2025 • Taxindo Prime Consulting

VAT Dispute on Fixed Asset Disposal (Article 16 D)

PUT-004528.16/2024/PP/M.IB of 2025 - August 4, 2025

Decision
November 05, 2025 • Taxindo Prime Consulting

Entertainment & Phone Expenses Disallowed, Tax Credit Questioned: When Does Administration Triumph Over Substance?

PUT-006770.15/2024/PP/M.XVA Tax Year 2021 – July 7, 2025

Decision
November 05, 2025 • Taxindo Prime Consulting

Zero Tax for PBG: Determination of Withholding Agents for Income Tax Article 23 in Freight Forwarder Transactions

PUT-004900.122021PPM.XVIIIA Year 2025 - July, 8 2025

Decision
November 05, 2025 • Taxindo Prime Consulting

VAT for Bonded Zone Rejected by the Panel: Code 070 Tax Invoice Is Not Enough, BC 4.0 Is Mandatory

PUT-010298.16/2021/PP/M.IIB Of 2025 - 1 Agustus 2025

Decision
November 04, 2025 • Taxindo Prime Consulting

Rebate Already Withheld Under Article 23 but Still Adjusted?

PUT-011197.15/2023/PP/M.XVIB Tahun 2025 - 21 Agustus 2025

Decision
October 31, 2025 • Taxindo Prime Consulting

Establishing Permanent Establishment Due to Long-Term Operational Control in SOSA: The Case of Hyatt Hotel India

(Civil Appeal No. 9766 Of 2025, July 24, 2025)

Decision
October 31, 2025 • Taxindo Prime Consulting

Ready Mix Tax Invoice Issued When Invoice is Issued? Tax Court Rejects 28-Day Quality Test Pretext, Input VAT on Ready Mix BKP Denied

PUT 003254.16.2020.PP.M.XIVA Tahun 2022 Dated Oktober 31, 2022

Decision
October 31, 2025 • Taxindo Prime Consulting

Contract Administration "Batched" into One Day Fails to Convince Judges: IDR 509 Million VAT on Dredging Services Denied Due to Late FPM

PUT 003254.16.2020.PP.M.XIVA Tahun 2022 Dated Oktober 31, 2022

Decision
October 15, 2025 • Taxindo Prime Consulting

Losing the Appeal at the Tax Court Due to the Independence Indicator

PUT-116551.15/2014/PP/M.XIIIB Tahun 2019 - 14 Mei 2019

Decision
October 13, 2025 • Taxindo Prime Consulting

Russian Comparables Rejected, Profit Adjustment to Q3 Must Be Justified

PUT-000036.15/2020/PP/M.IIB Year 2025 Dated July 7, 2025

Decision
October 11, 2025 • Taxindo Prime Consulting

Selective Litigation: A Crucial Lesson from the Panel's Upheld VAT Correction on Insurance Claims

PUT-004077.16/2024/PP/M.XXB Tahun 2025

Decision
October 11, 2025 • Taxindo Prime Consulting

The Obligation for Risk Assessment and Corresponding Adjustment in the Domestic Transfer Pricing Dispute of PT MHP

PUT-000765.15/2023/PP/M.XIVA Tahun 2024 Tanggal 17 Januari 2024

Decision
October 10, 2025 • Taxindo Prime Consulting

When a Tax Invoice is Unilaterally Canceled by the Seller, Is the Buyer's Right to Credit Input VAT Forfeited?

PUT-003932.16/2022/PP/M.XIA Year 2025 - June 03, 2025

Decision
October 10, 2025 • Taxindo Prime Consulting

Creditability Dispute of Normal Tax Invoices After Replacement Issued: Limitations of VAT Administrative Formalities

PUT-003932.16/2022/PP/M.XIA Tahun 2025 - 03 Juni 2025

Decision
October 10, 2025 • Taxindo Prime Consulting

Deductibility of Input VAT: Lessons from Sponsorship and Merchandise Costs

PUT-003932.16/2022/PP/M.XIA Year 2025 - 03 June 2025

Decision
October 09, 2025 • Taxindo Prime Consulting

Scrap Income Must Be Included in TNMM Operating Profit for PT. UMSI

PUT-015863.15/2020/PP/M.VIB - June 16, 2022

Decision
October 08, 2025 • Taxindo Prime Consulting

Cost of Goods Sold Dispute of PT AT: When Accounting Evidence Is Not Convincing Enough for the Tax Judge

PUT-000431.15/2021/PP/M.IA Tahun 2025 - 09 Juli 2025

Decision
October 08, 2025 • Taxindo Prime Consulting

PT AT's "Other" Business Expenses: An Expensive Lesson from the "Trash Can" Account in Tax Court

PUT-000431.15/2021/PP/M.IA Tahun 2025 - 09 Juli 2025

Decision
October 08, 2025 • Taxindo Prime Consulting

Non-Imposition of VAT on Inbreng (Capital Contribution in Kind): Literal vs. Substantial Interpretation at the Tax Court

Putusan Nomor PUT-001968.16/2023/PP/M.XIIIA Tahun 2025

Decision
October 07, 2025 • Taxindo Prime Consulting

Courier Service Equated with Expedition Service: PT PL Still Obligated to Withhold PPh Article 23

PUT-003925.12/2022/PP/M.XIA Tahun 2024 - 09 Desember 2024

Decision
October 07, 2025 • Taxindo Prime Consulting

E-Faktur Data Alone Is Not Enough: Tax Court Annuls PPh 23 Correction Based on Third-Party Data in the Case of PT PL

PUT-003925.12/2022/PP/M.XIA Tahun 2024 - 09 Desember 2024

Decision
October 07, 2025 • Taxindo Prime Consulting

Substance Over Formality: Tax Court Ruling Affirms Sales Discount Is Not Income for PT AI

PUT-001181.15/2023/PP/M.IXA Tahun 2024 - 30 Januari 2024

Decision
October 07, 2025 • Taxindo Prime Consulting

Differing Functions of Comparable Companies: Tax Court Annuls DJP's Transfer Pricing Correction

PUT-001181.15/2023/PP/M.IXA Tahun 2024 - 30 Januari 2024

Decision
October 07, 2025 • Taxindo Prime Consulting

PT. JHHPs Management Service Fee Correction and the High Standard of Proof for Intra-Group Services

PUT-000647.15/2023/PP/M.VIB Tahun 2024 - 12 Juli 2024

Decision
October 06, 2025 • Taxindo Prime Consulting

Sales Incentive is Not an Award: Tax Court Annuls PPh Article 23 Correction on Volume Discounts PT PL

PUT-003925.12/2022/PP/M.XIA Year 2024 - 09 December 2024

Decision
October 06, 2025 • Taxindo Prime Consulting

Goods or Services Transaction? PPh Article 23 Risk on PT PL's Custom Label Sticker Procurement PT PL

PUT-003925.12/2022/PP/M.XIA Tahun 2024 - 09 Desember 2024

Taxindo Prime Consulting (TPC) is a firm specializing in tax, accounting, business, and business law consulting.
Taxindo Prime Consulting (TPC) is established as a trusted strategic partner, providing comprehensive solutions in tax consulting, accounting, business development, and business law. Driven by a commitment to integrity and professionalism, TPC is dedicated to delivering more than just standard consultation; we provide education, tactical advice, and concrete solutions. Our services are meticulously designed to analyze and resolve clients' tax and business challenges with objectivity, in-depth insight, and full independence, ensuring both regulatory compliance and long-term business sustainability.
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