Salary equalization techniques are often a "deadly weapon" for tax authorities to find underpayments in Article 21 Income Tax. However, not all equalization results are accurate. In a recent case decided in August 2025, PT AHL successfully saved the company's cash flow by proving that the tax examiner's calculations contained a fatal flaw: double counting.
This case started when the DGT issued a notice of tax underpayment amounting to IDR 2.07 billion for Article 21 Income Tax. The examiner claimed the company had not withheld tax on various allowances such as fuel allowance and maid allowance. The basis of the tax authority's argument was that the data in the Corporate Tax Return appeared larger than the Article 21 reports. The company did not remain silent. They presented comparative data proving that the figures used by the tax authority as the calculation base actually already included all those allowances. This meant the tax authority was adding the same components twice! The company admitted there was indeed a difference, but the value was "only" IDR 66 million, far below the billions claimed by the tax authority.
In the trial, the Panel of Judges dissected the working papers of both parties. The judges agreed with the Taxpayer: the tax authority's equalization technique proved invalid because it added back costs that were already present. As a result, the massive correction was largely annulled by the Tax Court.
This victory teaches one crucial thing: do not simply accept the examiner's equalization results. Tidy bookkeeping data and detailed reconciliation between Salary Expenses in Financial Statements and Article 21 Tax Returns are the strongest shields. If you can prove that the difference in figures is merely a matter of account classification and not a hidden tax object, you have a great chance of winning in Court.
A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here.
tpc.consulting 
tpc.consulting 
info@taxindo.co.id