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

The Tax Court has once again affirmed its role as the guardian of legal certainty in tax administration through Decision Number PUT-006379.99/2024/PP/M.IVB Year 2025, which ruled in favor of PT TOI in a dispute over the determination of the useful life of tangible non-building assets. The dispute began when the company submitted a request for the determination of the useful life group for its Floating Processing Unit (FPU) assets as the basis for fiscal depreciation. However, the Central Jakarta Regional Tax Office issued a Notification Letter stating that the request could not be considered, followed by Decision KEP-213/WPJ.06/2024 rejecting the request. This situation prompted the company to take legal action through the Tax Court because it believed that the decision was inappropriate both procedurally and substantively.

In examining the dispute, the Panel of Judges traced the administrative chronology of the application and found that the first application submitted by the company had been legally accepted by the tax authorities but had not been followed up in accordance with the procedures set out in PMK-72/2023. The regulation explicitly states that if an application is declared complete, the DGT is required to issue a decision (approval or rejection) within a maximum of 10 working days. If the deadline passes without a decision, the application is deemed approved and an approval decision must be issued. In this case, the DGT not only failed to issue a request for additional information first, but also issued a Rejection Decision after the deadline had passed, so that legally the requested benefit period must be considered approved.

The Panel of Judges considered that this administrative action had caused a loss of taxpayer rights and was contrary to the principle of legal certainty. On that basis, the Tax Court decided to grant all of PT TOI's claims and revoke Decision KEP-213/WPJ.06/2024. Through this ruling, the company is legally entitled to use the asset benefit period as requested for fiscal depreciation purposes.

This ruling sends an important message to the business world and tax practitioners that tax administration mechanisms should not be ignored. It is not only the technical substance of the asset that is decisive, but also the accuracy of procedures, timing, and documentation. For taxpayers who apply for the determination of the useful life group, keeping proof of receipt and paying close attention to administrative deadlines are strategic steps to protect their tax rights. On the other hand, this case also serves as a reminder to the tax authorities of the importance of consistent implementation of PMK-72/2023 so that the relationship between the tax authorities and taxpayers is fair and professional.

With this ruling, PT TOI not only won the dispute, but also set a strong precedent that tax justice can be upheld through a transparent and objective legal process. For other taxpayers, this is a signal that administrative rights are part of compliance and should be fought for if there is treatment that does not comply with the provisions.

A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here