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Indonesia Inggris Member Area

Mismatched AR Flow? Lessons from PT NBI’s Foreign Exchange Case that Won the Tax Appeal.

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

PUT-009942.15/2022/PP/M.IIB for 2025

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Mismatched AR Flow? Lessons from PT NBI’s Foreign Exchange Case that Won the Tax Appeal.

PT NBI Turnover Dispute: Account Receivable Flow Test vs. Foreign Exchange Rate Volatility

Precision in mapping nominal accounts in financial statements is a primary determinant of a taxpayer's success in defending arguments during a field audit. The positive correction of business turnover amounting to USD 796,946.73 carried out by the Respondent on PT NBI stemmed from a failure to synchronize the account receivable (AR) flow test with the tax return reporting. The Respondent assumed the discrepancy between AR settlements and sales records was hidden turnover, ignoring the exchange rate volatility inherent in foreign currency-denominated transactions.

Core Conflict and Judicial Considerations: AR Flow Test Analysis and Foreign Exchange Impact

The core of this conflict centered on the interpretation of accounting data where the Respondent used a rigid mathematical approach in the AR flow test to establish additional income. On the other hand, PT NBI argumentatively proved that the difference was purely a foreign exchange difference that had factually been reported in the non-operating income post. The Board of Judges, in their consideration, agreed with the Petitioner’s argument after verifying the general ledger and profit and loss statements, thus deciding the correction had no legal basis. This ruling confirms that AR flow tests must not be conducted partially without looking at the interconnectedness of financial statement posts, especially the impact of exchange rate differences.

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


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PUT-001999.15/2020/PP/M.IIIA Year 2022

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Tax Court Appeal Decision | PPN | Partially Granted

PUT-001709.16/2018/PP/M.VIIIA Year 2019

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

PUT-001102.16/2018/PP/M.XVA Year 2019

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Tax Court Appeal Decision | PPN | Partially Granted

PUT-000831.162020PPM.XIA Year 2024

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Tax Court Appeal Decision | PPN | Fully Granted

PUT-000829.16/2020/PP.MXIA Year 2024

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

PUT-000819.152020PPM.XIA Year 2024

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Tax Court Appeal Decision | KUP | Inadmissible

PUT-000299.16/2019/PP/HT.II Year 2019

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Tax Court Appeal Decision | PPN | Fully Granted

PUT-000085.16/2019/PP/M.IIIA Year 2025

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Tax Court Appeal Decision | PPN | Fully Granted

PUT-000083.16/2018/PP/M.XVA Year 2019

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Tax Court Appeal Decision | PPN | Partially Granted

PUT-000024.16/2023/PP/M.IB Year 2025

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