OJK Reports Are Not Tax Determinants! How PT TF Won the Receivable Flow Dispute at the Tax Court.

Business Circulation Correction Dispute of PT TF: LBPP OJK Data vs. Audited Financial Statements

In tax audit practices, tax authorities often use external data as a benchmark for revenue extrapolation through the receivable flow test method. This dispute focuses on the validity of using Monthly Finance Company Reports (LBPP) submitted to the Financial Services Authority (OJK) as the basis for a IDR 2.8 billion positive correction of PT TF's business circulation. The Respondent insisted on an unreconciled cash inflow discrepancy in the Annual Tax Return, while the Petitioner asserted that tax reporting must be based on Audited Financial Statements, which hold higher legal standing and accuracy in fiscal accounting.

The Core Conflict: Unaudited Sectoral Supervision Data vs. Rigorous Independent Audit Reconciliation

The conflict centered on data reliability. The Respondent used unaudited LBPP OJK data intended for industry supervision. Conversely, the Taxpayer proved that every figure in the Tax Return had undergone rigorous reconciliation by independent auditors.

Judges' Legal Considerations: Primary Reference of Audited Books Under Article 28 of the KUP Law

The Board of Judges, in its consideration, explicitly stated that according to Article 28 of the KUP Law, audited books are the primary reference for determining tax liability. The Judges ruled that using LBPP OJK data without deep reconciliation cannot serve as a valid basis for correction. This decision provides legal certainty for the financial industry that sectoral supervision data cannot be automatically annexed as a taxation basis without strong material evidence.

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