Concrete Data: Accelerating Tax Compliance Enforcement Through Direct Evidentiary Mechanisms

In the tax reform marked by the implementation of the Coretax System, the Directorate General of Taxes (DGT) is moving towards more efficient and data-driven supervision. One crucial element in this new paradigm is the concept of "Concrete Data" (Data Konkret). Concrete Data is not just ordinary data; it is data possessing such evidentiary strength that it can be directly used to calculate tax liabilities without the need for convoluted testing.

Under the regime of MoF Regulation (PMK) Number 15 of 2025 and its implementing regulation PER-18/PJ/2025, Concrete Data becomes the primary basis for Specific Audit (Pemeriksaan Spesifik), a new type of audit designed for speed and legal certainty. This article will dissect the definition, scope, follow-up mechanisms, and examples of Concrete Data application.

1. Definition and Philosophy of Concrete Data

Philosophically, Concrete Data is mature data. Unlike trigger data (such as ratio analysis or IDLP) which still requires deep clarification and validity testing, Concrete Data is considered to represent the facts of actual economic events.

The main characteristics of Concrete Data are:

1. High Validity: The data does not require complex physical verification.
2. Direct Calculation: Tax authorities can directly calculate the underpaid tax just by looking at the data.
3. Fast Follow-up: This data triggers a very short audit mechanism (Specific Audit) or the issuance of a Tax Collection Letter (STP) [PER-18/PJ/2025].

2. Scope of Concrete Data

Referring to Article 2 of PER-18/PJ/2025 and PMK 15 of 2025, the classification of Concrete Data has been simplified and clarified into the following categories:

A. Tax Invoices

This covers Output Tax Invoices that have received approval from the DGT information system (e-Faktur) but have not been or are not reported by the Taxpayer in the VAT Period Return. Since the e-Faktur system is online and real-time, the DGT has definite data that the Taxpayer has issued an invoice, so if it is not in the Tax Return, it is a concrete deviation.

B. Withholding/Collection Slips

Data in the form of Income Tax withholding/collection slips issued by the tax withholder (Taxpayer) but not reported in the Income Tax Period Return. For example, a company issues Article 21 Income Tax withholding slips for employees or Article 23 for vendors, the data enters the DGT system, but the Taxpayer does not file their Income Tax Period Return.

C. Non-Filing Taxpayer Data (After Warning)

This is tax data related to Taxpayers who do not submit Tax Returns (Period or Annual) within the specified time, and after being warned in writing, the Taxpayer still does not submit them. In this context, transaction data held by the DGT (e.g., from counterparties) is considered concrete for calculating tax ex-officio.

D. Transaction Proofs or Other Data

Other data that can be directly used to calculate tax liabilities, such as data that has been clarified through SP2DK (Request for Explanation on Data and/or Information) and the Taxpayer admits its truth but does not correct the Tax Return [PER-18/PJ/2025; SE-9/PJ/2023].

3. Follow-up Mechanism: Specific Audit

The specialty of Concrete Data lies in its audit procedure. In PMK 15 of 2025, Concrete Data is followed up through Specific Audit (Pemeriksaan Spesifik).

• Super Short Duration: While a normal audit (Comprehensive) can take months, a Specific Audit for Concrete Data has a testing period of only 10 (ten) working days and a reporting period of 10 (ten) working days [PMK 15 Year 2025].
• Simple Procedure: This audit is usually conducted via Office Audit.
• No Discussion of Temporary Findings: Because the data is considered certain, the Discussion of Temporary Findings stage (before SPHP) which commonly exists in other audits, is eliminated for Specific Audits of concrete data.

4. Application Examples and Case Studies

Here are illustrations of how Concrete Data works in practice:

5. Implications for Taxpayers

With the enactment of PER-18/PJ/2025 and the Coretax system, the room to "hide" formal transactions is narrowing. Taxpayers must:

1. Routine Reconciliation: Ensure every successful Tax Invoice approval and issued Withholding Slip enters the Period Tax Return.
2. Quick Response: If receiving SP2DK related to concrete data, respond immediately to avoid fast specific audits.
3. Digitalization: Use accounting systems integrated with tax applications to minimize human error.

Conclusion

Concrete Data is an instrument of efficiency in Indonesian tax law. It cuts audit bureaucracy for cases where the facts are crystal clear. For the DGT, this is a revenue optimization tool. For Taxpayers, this is a stern warning that administrative non-compliance (such as forgetting to report invoices) will have direct and rapid financial consequences under the umbrella of PMK 15 of 2025.

Reference:

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