Introduction
A new era of Indonesian tax administration has begun with the implementation of the Core Tax Administration System (Coretax). One of the most fundamental changes felt by Corporate Taxpayers is the mechanism for filling out the Annual Tax Return (SPT). This system moves away from the old static form-based method (e-Form) towards an integrated data-based system.
One area undergoing significant transformation is the filling of Attachment 2 (L2) regarding the List of Shareholders. In the old system, Taxpayers could manually type the names of foreign shareholders or upload CSV files every time they reported the SPT. However, in Coretax, this data is now Prepopulated (automatically filled) sourced from the Taxpayer's registration profile data (Master File).
This often causes confusion: "Why can't I type the name of a new shareholder in the SPT form?" The answer is because Coretax adheres to the Single Source of Truth principle. Identity data must be changed upstream (Taxpayer Profile), not downstream (SPT). This article will discuss in depth how to add foreign shareholders (both Entities and Individuals) so that they appear automatically in the Annual SPT, along with case illustrations.
Legal Basis and Regulatory References
This procedure is based on the following legal frameworks and technical guidelines:
- Minister of Finance Regulation Number 81 of 2024 regarding Tax Provisions for the Implementation of the Core Tax Administration System.
- Director General of Taxes Regulation Number PER-11/PJ/2025 regarding the Form, Content, and Procedures for Filling the Annual Income Tax Return for Corporate Taxpayers. This regulation stipulates that Attachment 2 (List of Ownership) is filled based on the conditions at the end of the tax year and the data is integrated with the Taxpayer's profile.
- Coretax Manual Module 2024 - Taxpayer Data Update, which explains the technicalities of adding "Related Parties" including foreign shareholders.
The "Prepopulated" Concept in Attachment 2
In Coretax, Attachment 2 (L2) - List of Shareholders, Dividend Distribution, and List of Management and Commissioners, no longer stands alone as a free-entry form.
Mechanism Differences:
- Old System: Taxpayers input the name "Global Corp Ltd" directly in the SPT attachment. If reporting again next year, they must re-input or re-import. There is no validation of whether the entity actually exists in the DGT database.
- Coretax System: Taxpayers open the SPT, and the system immediately pulls data from the Taxpayer Profile > Related Parties menu. If there is a new foreign shareholder who has not been registered in the Profile menu, their name will not appear in the SPT and the Taxpayer cannot add it manually in the SPT form.
Therefore, the first step to reporting foreign shareholders does not start from the "Annual SPT" menu, but from the "Data Update" menu.
Steps to Add Foreign Shareholders
Here is the technical procedure to register foreign shareholders so they populate into the SPT:
1. Login and Profile Access
- Log in to the Coretax portal (coretax.pajak.go.id).
- Log in using the Management/PIC account.
- Perform Impersonating (acting on behalf of) to your Corporate Taxpayer account.
- Go to the My Portal > My Profile > General Information menu.
2. Related Parties Menu
- Scroll down until you find the Related Parties section.
- Click the Edit button at the top right of the profile page to open editing access.
- In the Related Parties table, click the Add button.
3. Filling in Foreign Shareholder Data
A pop-up form will appear. Filling for foreign subjects is different from domestic subjects. Here are the details based on system guidelines:
- Related Person Type: Select Shareholder.
- Sub Related Person Type:
- Select Foreign Entity (Badan Luar Negeri) if the shareholder is a foreign company.
- Select Foreign Individual (Orang Pribadi WNA) if the shareholder is a foreign individual.
- Identity Number (TIN/Passport):
- For Entities: Enter the Tax Identification Number (TIN) of the country of origin. If unavailable, the system might allow entering a dash (-), but entering a TIN is recommended for Exchange of Information purposes.
- For Individuals: Enter the Passport Number.
- Person Name: Fill in the full name of the foreign company or individual according to legal documents.
- Country of Origin: Select the shareholder's domicile country from the dropdown menu.
- Share Classification: Select the type of share (e.g., Common Stock).
- Share Percentage: Enter the ownership percentage (e.g., 40).
- Start Date: Fill in the effective date of share ownership according to the Deed or GMS.
Important Note: For Foreigners/Foreign Entities that do not have an Indonesian NPWP, Coretax provides flexibility not to require an NPWP, but replaces it with a TIN or Passport as their Primary Key identity in the system.
4. Save and Validate
- After all data is filled, click Save.
- Click Submit on the profile data change request. The system will process the master file update.
5. Synchronization in Annual SPT (Posting)
After the profile data is successfully updated:
- Go to the Annual SPT menu.
- Open the SPT Draft you are working on.
- Click the "Posting SPT" button or data refresh button.
- Open Attachment 2 (L2). Automatically, the name of the foreign shareholder you just input in the profile will appear in the SPT table.
- Inside Attachment 2 of the SPT, you only need to complete transactional data such as the Total Dividend distributed in that year (if any). The name identity and share percentage will be locked (read-only) according to the profile data.
Case Illustration
To clarify, let's use the following case study:
PT Teknologi Nusantara is a PMA (Foreign Direct Investment) company in Jakarta. On July 1, 2025, there was a change in the share ownership structure. A new investor from Singapore, Temasek Tech Pte. Ltd., purchased 45% of the company's shares.
When the tax staff of PT Teknologi Nusantara wants to report the 2025 Annual SPT in Coretax, here are the steps that must be taken:
Table 1: Comparison of Actions in Old System vs Coretax
| Aspect |
Old System (e-Form PDF) |
Coretax System |
| Input Location |
Type directly in Attachment V (List of Shareholders) on the PDF file. |
My Profile > Related Parties menu. Cannot type in SPT. |
| Foreign Identity |
Often the NPWP column is filled with 00.000.0000-000 or left blank. |
Mandatory to fill in Tax Identification Number (TIN) of Singapore or Passport Number (if individual). |
| Validation |
No validation of whether the entity is valid. |
Data format validation (Country, Email, Phone No) during profile input. |
| Impact on SPT |
Data is saved only in that year's SPT file. |
Data is saved in the DGT Master File and will automatically appear (prepopulated) in future SPTs. |
Table 2: Simulation of Data Input in Coretax Profile (Related Parties)
| Coretax Field |
PT Teknologi Nusantara Input Data |
Remarks |
| Related Person Type |
Shareholder |
Must be selected |
| Sub Type |
Foreign Entity (Badan Luar Negeri) |
Key to changing NPWP column to TIN |
| Person NIK/TIN |
200512345K (Example Singapore UEN) |
Filled with origin country tax number |
| Person Name |
Temasek Tech Pte. Ltd. |
Legal entity name |
| Nationality/Country |
Singapore |
Domicile country |
| Email |
tax@temasektech.sg |
Entity contact email |
| Phone Number |
+65 6789 1234 |
International phone number |
| Share Percentage |
45 |
Ownership percentage |
| Start Date |
01-07-2025 |
Effective entry date |
After the data above is saved in the Profile, when opening Attachment 2 of the Annual SPT, the row for Temasek Tech Pte. Ltd. will appear automatically. The tax staff just needs to input the dividend (if any).
Implications Related to Other Documents (TP Doc & CbCR)
Adding foreign shareholders in Coretax does not only affect Attachment 2. Since this system is integrated, this addition can trigger other reporting obligations if conditions are met, especially regarding Transfer Pricing:
- Attachment 10 (Related Party Transactions): If there are transactions with that foreign shareholder (e.g., royalty payments or management fees), this shareholder data will be a reference in Attachment 10.
- CbCR Notification (Country-by-Country Report): If the foreign shareholder is the Ultimate Parent Entity of a business group with a certain consolidated turnover, Coretax might notify the obligation to submit CbCR or CbCR Notification, which menu is now integrated in the dashboard.
- Income Tax Article 26 Withholding Slip: If there is a dividend payment to a foreign shareholder, you must create an Art. 26 Withholding Slip in the Unified e-Bupot menu. The withholding slip recipient data (Foreign Shareholder) in e-Bupot should ideally be synchronized with the registered Related Party data.
Conclusion
Adding foreign shareholders in the Coretax Corporate Annual Income Tax Return requires a shift in work patterns from "filling forms" to "managing profile data". The prepopulated feature in Attachment 2 forces Taxpayers to be more disciplined and real-time in updating organizational data.
The key to success is: Update Profile First, Create SPT Later. Do not wait for the SPT reporting period to end to update foreign shareholder data, because the impersonating and profile update process requires valid authorization. With accurate profile data, SPT filling will be much faster and free of input errors.
Regulatory References
- Minister of Finance Regulation Number 81 of 2024 regarding Tax Provisions for the Implementation of the Core Tax Administration System.
- Director General of Taxes Regulation Number PER-11/PJ/2025 regarding the Form, Content, and Procedures for Filling the Annual SPT.