Anatomy of Concrete Data: A Thorough Dissection of Classifications and Implications of Direct Evidence in the Latest Tax Audit Regime

In the evolution of tax governance in Indonesia, particularly in welcoming the full implementation of the Coretax System, the Directorate General of Taxes (DGT) has strategically redefined its supervision and audit mechanisms. One of the main pillars in accelerating this law enforcement is the concept of "Concrete Data" (Data Konkret).

Based on MoF Regulation (PMK) Number 15 of 2025 and its implementing regulation PER-18/PJ/2025, Concrete Data is no longer merely trigger data; it is data possessing absolute material evidentiary weight. This data enables tax authorities to calculate tax liabilities directly without going through lengthy and convoluted testing processes. This article will narratively and deeply outline the classifications of Concrete Data types as regulated in the latest regulations, and how such data is transformed into legal products.

1. Fundamental Concept of Concrete Data in the Modernization Era

Significant changes have occurred in its handling. While previously the handling of concrete data often took months through ordinary Special Audit mechanisms, now under PER-18/PJ/2025, this data is executed through a Specific Audit (Pemeriksaan Spesifik). This audit is characterized by its "lightning" speed, with a testing period of a maximum of only 10 (ten) working days [PER-18/PJ/2025]. This is made possible because the nature of the data is considered mature and does not require complex external confirmation.

2. Classification of Concrete Data Types Based on PER-18/PJ/2025

Referring to Article 2 of PER-18/PJ/2025, there are four main categories classified as Concrete Data. Below is an in-depth analysis for each type:

A. Output Tax Invoices (System Validation vs. Reporting)

The first and most common type relates to Value Added Tax (VAT).

• Definition: Tax Invoices that have received approval from the DGT's information system but have not been or are not reported by the Taxpayer in the VAT Period Return [PMK 15 Year 2025, Article 5 paragraph 2; PER-18/PJ/2025].
• Detection Mechanism: In the e-Faktur ecosystem, every invoice issuance must receive QR Code validation from the DGT server. This digital footprint is recorded perfectly in the DGT database. When the system performs matching between approved invoice data and the VAT Return data reported by the Taxpayer, any discrepancy is immediately identified as Concrete Data.
• Example: PT A issues a Tax Invoice with VAT of IDR 100 million in the January 2025 period and it is successfully uploaded (approved). However, in the January 2025 VAT Return, PT A reports nil or under-reports. This IDR 100 million discrepancy is Concrete Data that cannot be refuted.

B. Withholding Tax Slips (Withholding Tax Obligations)

The second type relates to Withholding Tax (Potput) obligations.

• Definition: Withholding/collection slips that have not been or are not reported by the issuer of the withholding/collection slip in the Income Tax Period Return [PER-18/PJ/2025, Article 2 paragraph 1 letter b].
• Detection Mechanism: Through the e-Bupot Unification system, Taxpayers create withholding slips that are automatically stored on the DGT server. If a Taxpayer has issued a withholding slip but forgot or deliberately did not report it, then that data becomes Concrete Data.
• Implication: Authorities do not need to test whether the transaction actually occurred, because the issuance of the withholding slip is a unilateral admission by the Taxpayer.

C. Non-Filer Taxpayer Data (Post-Warning)

The third type targets Taxpayers who are formally non-compliant but have traces of economic transactions. When a Taxpayer ignores the Tax Return Submission Warning Letter, the transaction data possessed by the DGT "upgrades status" to Concrete Data which can be directly used to calculate tax payable ex-officio.

D. Transaction Proofs or Other Data (Result of Clarification)

This is the most dynamic category. Data that was initially "trigger data" can transform into "concrete data" through the supervision process.

Article 2 paragraph (2) of PER-18/PJ/2025 details that this includes data/information that has been:

1. Issued an SP2DK (Request for Explanation on Data and/or Information); AND
2. Created a Minutes (Berita Acara) of request for explanation containing the Taxpayer's agreement/admission on the fulfillment of tax obligations; BUT
3. The Taxpayer fails to pay or correct the Tax Return by the agreed deadline.

3. Procedural Implications: Speed Above All

Determining data as Concrete Data brings procedural consequences that are vastly different from ordinary audits:

• Specific Audit: Concrete Data is audited through the Specific Audit type [PMK 15 Year 2025].
• No Preliminary Findings Discussion: This stage is eliminated. Taxpayers will immediately receive the Notification of Audit Results (SPHP).
• Very Short Time: Examiners only have 10 working days for testing and 10 working days for reporting.

Conclusion

The latest regulations via PER-18/PJ/2025 and PMK 15 of 2025 have clarified the boundaries and types of Concrete Data. From "lost" Tax Invoices, unreported Withholding Slips, to Taxpayer admissions in SP2DK Minutes that are reneged upon, all now have an express lane to tax assessment (SKP).

For tax practitioners and Taxpayers, this understanding is crucial. Ignoring system data validation (e-Faktur/e-Bupot) or underestimating commitments in SP2DK Minutes no longer just risks a re-summon, but directly faces a fast and binding Specific Audit.

Reference:

1. Law Number 6 of 1983 as amended lastly by Law Number 6 of 2023 (UU KUP).
2. Government Regulation Number 50 of 2022.
3. Minister of Finance Regulation Number 15 of 2025 concerning Tax Audit.
4. Director General of Taxes Regulation Number PER-18/PJ/2025 concerning Follow-up on Concrete Data.
5. Director General of Taxes Regulation Number PER-23/PJ/2013 concerning Audit Standards.
6. Director General of Taxes Circular Letter Number SE-09/PJ/2023.
7. Director General of Taxes Circular Letter Number SE-15/PJ/2018.