The application of Article 4 paragraph (1) letter f of the VAT Law, which governs the taxation of exported Taxable Goods, routinely turns into an aggressive litigation arena when the tax authority relies on partial external data, such as Export Declaration (PEB) logs, to adjust the primary Tax Base (DPP).

In the case study of Tax Court Decision Number PUT-004522.16/2024/PP/M.IB Year 2025, the Director General of Taxes (DGT) established an Export Turnover correction totaling IDR 28.33 billion by relying strictly on automated PEB transaction records obtained via information exchanges with the Directorate General of Customs and Excise. The DGT argued that this data de jure proved that the Applicant had executed cross-border shipments that escaped corporate tax reporting.

The Applicant, PT LI, brought forward a crucial material rebuttal demonstrating that the disputed PEB records factually belonged to an entirely separate corporate entity and were completely disconnected from the Applicant's commercial infrastructure.

The Applicant's defense focused on proving a vacant internal accounting ledger—showing a total absence of corresponding trade receivables, cash entries, or Cost of Goods Sold (COGS) adjustments. In other words, while the Applicant's corporate name might have appeared on the face of the formal customs forms, the economic substance confirmed that the Applicant never received any form of economic enrichment or cash flows.

The Board of Judges of the Tax Court explicitly ruled in favor of the substance over form doctrine presented by the Taxpayer.

The Court deliberated that external customs data presented by the Respondent functions merely as preliminary indicative evidence (bewijsaanwijzing). This indicative data lacks the standalone legal weight required to break down the integrity of a Taxpayer’s formal accounting system when supported by the General Ledger and complete financial cross-reconciliations. This decision powerfully reinforces the statutory rule written into Article 29 paragraph (2) of the UU KUP: the party executing a tax correction carries the absolute burden to prove its empirical accuracy. The DGT's failure to provide a cohesive main evidence trail, combined with unpredictable data variations during the trial, resulted in the total cancellation of the export adjustment.

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