VAT Appeal Win: Why Seller's Negligence Cannot Void Buyer's Right to Tax Credits?

Tax Court Appeal Decision | PPN | Fully Granted

PUT-001774.16/2019/PP/M.IIIA Year 2020

Taxindo Prime Consulting
Thursday, June 18, 2026 | 15:32 WIB
00:00
Optimized with Google Chrome
VAT Appeal Win: Why Seller's Negligence Cannot Void Buyer's Right to Tax Credits?

The Impact of Third-Party Administrative Failure on Input Tax Claims: PT TI VAT Dispute

The Value Added Tax (VAT) dispute involving PT TI focuses on the correction of Input Tax amounting to IDR 26,902,907.00 by the Respondent due to the administrative failure of a third party. The tax authority issued the correction after the Tax Invoice confirmation results were stated as "Non-Existent" because the Selling Taxable Person (PKP) had not reported the invoice in their VAT Return. The core of this conflict lies in the clash between the administrative procedure of invoice confirmation under KEP-754/PJ./2001 and the substance of transaction truth, as well as the principle of joint liability as regulated in Article 33 of the General Tax Provisions (KUP) Law and Article 16J of the VAT Law.

During the Trial PT TI Establishes Material Truth and Taxpayer Good Faith

During the trial, PT TI convincingly presented evidence of the flow of goods and money, proving that the VAT had been paid to the seller through the acquisition price mechanism. The Board of Tax Court Judges, in their legal consideration, emphasized that the buyer's right to claim input tax credits should not be forfeited solely due to the seller's negligence in reporting the tax already collected. This legal resolution was based on the fact that the appellant had fulfilled their tax obligations formally and materially, while the seller's failure is within the scope of the DGT's supervision and should not be burdened onto the buyer through joint liability instruments. The implication of this decision strengthens the protection for taxpayers acting in good faith, affirming that the material truth of a transaction remains paramount in input tax credit disputes.

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


August 05, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Partially Granted

PUT-007016.162024PPM.XVIIIB Year 2025

August 05, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | Income Tax Articles 23/26 (Final) | Partially Granted

PUT-007041.122024PPM.XVIIIB Year 2025

August 05, 2026 • Taxindo Prime Consulting

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

PUT-007042.122024PPM.XVIIIB Year 2025

August 05, 2026 • Taxindo Prime Consulting

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

PUT-007239.15/2023/PP/M.XIVA Year 2024

August 05, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Fully Granted

PUT-007248.162023PPM.XIVA Year 2024

August 05, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | Income Tax Articles 23/26 (Final) | To Reject the Appeal/ Lawsuit

PUT-009965.132022PPM.IIB Year 2025

August 04, 2026 • Taxindo Prime Consulting

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

PUT-010300.252023PPM.XIIIB Year 2025

August 04, 2026 • Taxindo Prime Consulting

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

PUT-010310.15/2021/PP/M.VIIIA Year 2025

August 04, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Fully Granted

PUT-010314.16/2021/PP/M.VIIIA Year 2025

August 04, 2026 • Taxindo Prime Consulting

Tax Court Appeal Decision | PPN | Partially Granted

PUT-010315.162021PPM.VIIIA Year 2025

Article More Details
August 24, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

August 24, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

August 24, 2026 • Taxindo Prime Consulting | Adv Muhammad Faiz Nur Abshar, S.H. - Lilik F Pracaya, Ak., CA., ME., BKP (C)

Taxindo Prime Consulting (TPC) is a firm specializing in tax, accounting, business, and business law consulting.
Taxindo Prime Consulting (TPC) is established as a trusted strategic partner, providing comprehensive solutions in tax consulting, accounting, business development, and business law. Driven by a commitment to integrity and professionalism, TPC is dedicated to delivering more than just standard consultation; we provide education, tactical advice, and concrete solutions. Our services are meticulously designed to analyze and resolve clients' tax and business challenges with objectivity, in-depth insight, and full independence, ensuring both regulatory compliance and long-term business sustainability.
OFFICE
Mega Plaza Building 12th Floor
Jl. H.R. Rasuna Said Kav C-3 Jakarta 12940

Phone :
+62 21 521 2686
+62 817 001 3303

Email :
info@taxindo.co.id
Copyright © 2026 Taxindo Prime Consulting

All content on this website is provided solely for general informational and educational purposes. This information is not intended as a substitute for professional tax advice or consultation specific to your situation. We strongly encourage you to contact our team of consultants directly to receive appropriate guidance and advice.

Taxindo Prime Consulting
Tax and Transfer Pricing Calculator
Tax Calendar
×
Newsletter