The interest reward dispute between PT. AICC and the DGT serves as a crucial precedent regarding the transition of interest reward procedures post-Omnibus Law. The conflict centers on a fundamental question: does the right to interest reward follow the tax year of the dispute (2017) or the law in effect at the time of the court decision (2022)?
The Karawang Tax Office rejected a IDR 91.9 million interest reward request. The DGT argued that based on PMK-18/2021, any decision rendered after November 2, 2020, must follow Article 27B of the Omnibus Law. PT. AICC countered that since the audit concerned the 2017 tax year, the old Article 27A KUP Law should apply, which was much broader in granting interest.
The Board of Judges sided with the DGT by applying the principle of tempus regit actum (the time governs the act). Since the Appeal Decision was rendered in 2022, the administrative procedure is strictly bound by the Omnibus Law. Because PT. AICC's original returns were in "Underpayment" status (self-paid) rather than "Overpayment," they limitatively failed to qualify for interest rewards.
This decision confirms that regulatory changes via the Omnibus Law have effectively narrowed the window for receiving interest rewards. A victory at the appeal level no longer automatically guarantees 2% monthly interest if the initial filing was not an Overpayment return. Taxpayers must now map financial risks more carefully, as court-ordered refunds may no longer include compensatory interest.
In conclusion, the PT. AICC case reinforces that legal certainty depends heavily on the timing of the court's decision. For corporations, this underscores that the "bonus" of interest rewards is now a rarity, reserved strictly for those who correctly positioned their SPT as an overpayment from the start.
A Comprehensive Analysis and the Tax Court Decision on This Dispute Are Available Here
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