The dispute arose when PT AI received Warning Letter Number S-00051/TGR-CT/KPP.1209/2025 via the Coretax platform. The Plaintiff filed a lawsuit, arguing that the document was legally flawed due to the use of an Electronic Seal without a clear official's identity and was issued prematurely while an objection process was still pending. The Plaintiff emphasized that transparency in digital systems must remain subject to the General Principles of Good Corporate Governance (AAUPB).
Conversely, the Directorate General of Taxes (Defendant) maintained that the Coretax system is legally underpinned by PMK 81/2024. The Defendant argued that a Warning Letter is a communication tool for tax collection intended as a reminder, not a decision that independently establishes a new tax liability, and thus cannot be classified as a final Administrative Decision (KTUN).
In its legal considerations, the Board of Judges took a firm stance regarding the Tax Court's absolute competence. The Judges opined that under Article 23 paragraph (2) of the KUP Law, only specific collection actions are subject to lawsuit. The Warning Letter was deemed a preparatory act (preparatoir) leading toward active collection stages (Distress Warrant/Surat Paksa). Since it is not determinative (beschikkings) and does not directly trigger final legal consequences for the taxpayer, the lawsuit was declared inadmissible (niet ontvankelijke verklaard).
This ruling sends a strong signal to Taxpayers that digitalization through Coretax enjoys broad procedural protection concerning non-final administrative documents. Taxpayers must understand that legal challenges through lawsuits are reserved for collection stages with executorial force, such as Distress Warrants or seizures.
A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here
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