Tax Court Victory: How PT BHI Proved That Bad Debt Interest Is Not Taxable Income

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

PUT-001821.35/2024/PP/M.IIIB Year 2025

Taxindo Prime Consulting
Friday, October 23, 2026 | 10:01 WIB
00:00
Optimized with Google Chrome
Tax Court Victory: How PT BHI Proved That Bad Debt Interest Is Not Taxable Income

The dispute between PT BHI and the Directorate General of Taxes (DGT) highlights the complexity of recognizing interest income on non-performing loans within Branch Profit Tax (BPT) calculations. The primary focus of this case is the DGT's interpretation of declining interest receivable balances as objects of Income Tax Article 26(4). The core conflict lies in the application of cash versus accrual basis, where the DGT assumed the reduction in interest balances was a cash receipt, while PT BHI asserted it resulted from debt write-offs or assignments.

In its legal consideration, the Board of Judges prioritized material truth by conducting a thorough examination of the company's bank statements. Consequently, it was proven that no fund inflows from debtors occurred regarding the NPL interest. The Court emphasized that without realized payments, the correction of interest income could not be upheld. This decision provides legal protection for the banking sector against taxes on income that has not been economically received.

The implication of this ruling for financial service providers is the critical importance of synchronizing banking accounting records with fund flow evidence to withstand tax equalizations. PT BHI successfully overturned the majority of the corrections due to the strength of specific transaction supporting documents.

A Comprehensive Analysis and the Tax Court

Decision on This Dispute Are Available Here


October 23, 2026 • Taxindo Prime Consulting

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

PUT-003085.16/2024/PP/M.IA Year 2025

October 23, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Partially Granted

PUT-003082.16/2024/PP/M.IA Year 2025

October 23, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PBB-P3 | To Reject the Appeal/ Lawsuit

PUT-002768.18/2024/PP/M.XVA Year 2025

October 23, 2026 • Taxindo Prime Consulting

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

PUT-002639.15/2023/PP/M.XIIB Year 2025

October 23, 2026 • Taxindo Prime Consulting

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

PUT-002122.15/2023/PP/M.IVB Year 2025

October 23, 2026 • Taxindo Prime Consulting

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

PUT-001820.15/2024/PP/M.IIIB Year 2025

October 23, 2026 • Taxindo Prime Consulting

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

PUT-001704.15/2020/PP/M.IVB Year 2025

October 23, 2026 • Taxindo Prime Consulting

Tax Court Lawsuit Decision | KUP | Inadmissible

PUT-001457.99/2023/PP/M.IB Year 2025

October 23, 2026 • Taxindo Prime Consulting

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

PUT-001380.16/2024/PP/M.IXA Year 2025

October 22, 2026 • Taxindo Prime Consulting

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

PUT-001347.99/2024/PP/M.XIIB Year 2025

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.
OFFICE
Mega Plaza Building 12th Floor
Jl. H.R. Rasuna Said Kav C-3 Jakarta 12940

Phone :
+62 21 521 2686
+62 817 001 3303

Email :
info@taxindo.co.id
Copyright © 2026 Taxindo Prime Consulting

All content on this website is provided solely for general informational and educational purposes. This information is not intended as a substitute for professional tax advice or consultation specific to your situation. We strongly encourage you to contact our team of consultants directly to receive appropriate guidance and advice.

Taxindo Prime Consulting
Tax and Transfer Pricing Calculator
Tax Calendar
×
Newsletter