Concrete Data Tax Audit (PMK 15/2025 & PER-18/PJ/2025)

Concrete Data is data obtained or possessed by the Director General of Taxes in the form of tax invoice data, withholding tax slip data, or net asset data that does not require further in-depth testing to calculate tax obligations. [PER-18/PJ/2025, Art. 1 no. 6; Slide Pg. 7]

Under PMK 15 of 2025, an audit of Concrete Data is categorized under the Specific Audit Type (Tipe Pemeriksaan Spesifik). [PMK 15 Year 2025, Art. 2 para 2; Transcript Pg. 314]

This audit is conducted using simple audit techniques and methods, focusing only on the items related to the concrete data. [PMK 15 Year 2025, Art. 1 no. 9; Slide Pg. 112]

There are 3 (three) main types of concrete data: related to unreported Tax Invoices/Withholding Slips, reported but unpaid/unremitted Tax Invoices/Withholding Slips, and Net Asset Data. [PER-18/PJ/2025, Art. 2]

It is data in the form of Tax Invoices or Tax Withholding/Collection Slips issued by the Withholder/Collector/VAT Registered Seller, but not yet reported by the Taxpayer (the party being withheld/buyer) in the Tax Return for the relevant tax period. [PER-18/PJ/2025, Art. 2 letter a]

It is data in the form of Tax Invoices or Withholding/Collection Slips that have been reported by the Taxpayer in the Tax Return, but the tax was not paid or underpaid. [PER-18/PJ/2025, Art. 2 letter b]

It is data on net assets that:

Have been reported in the Asset Declaration Letter (Tax Amnesty/Voluntary Disclosure Program); but

Have not been reported in the Last Annual Income Tax Return. [PER-18/PJ/2025, Art. 2 letter c]

No. Based on PER-18/PJ/2025, the criterion "Taxpayer fails to submit Tax Return after warning" has been removed from the Concrete Data category (unlike the old rules). This case will likely fall under Specific Audit (non-concrete) or Routine Audit. [Transcript Pg. 335; Analysis of PER-18/PJ/2025 Changes]

No. Equalization requires analysis and testing to find the cause of the discrepancy, so it does not meet the "does not require further testing" requirement. [Interpretation of PER-18/PJ/2025 Art. 2]

A maximum of 1 (one) month. [PMK 15 Year 2025, Art. 6 para 2 letter c]

Calculated from the date the Notice of Audit is delivered to the Taxpayer. [PMK 15 Year 2025, Art. 6 para 2]

A maximum of 10 (ten) working days. This is much shorter than other audit types (30 working days). [PMK 15 Year 2025, Art. 6 para 3 letter b; Transcript Pg. 315]

In principle, it cannot be extended due to the concrete nature of the data and simple techniques. PMK 15 Article 6 paragraph 5 limits extensions only to TP/Group/Financial Engineering issues. [PMK 15 Year 2025, Art. 6 para 5]

The Tax Auditor may be deemed to have violated the code of ethics or discipline, but the audit is not automatically legally void; rather, it must be completed immediately. The Taxpayer may file a complaint if there is undue delay. [General Procedural Analysis]

It depends on the assessment statute of limitations.

If the expiration is still far: Preceded by SP2DK (supervision).

If the expiration is < 90 days: Can be proposed for Concrete Data Audit immediately without SP2DK. [SE-9/PJ/2023 Letter E number 3 letter g]

In PMK 15/2025, the obligation for an explanation meeting (entry meeting) is exempted for Specific Audits (including Concrete Data). However, the Notice of Audit must still be delivered. [PMK 15 Year 2025, Art. 11 para 1 (implied); Transcript Pg. 312]

No. Article 17 paragraph (2) of PMK 15/2025 exempts the obligation to deliver interim results notifications and discussion of interim findings for Specific Audits (Concrete Data). The Auditor proceeds directly to issue the SPHP. [PMK 15 Year 2025, Art. 17 para 2; Transcript Pg. 331]

The Taxpayer is still given the opportunity to submit a written response to the Notification of Audit Results (SPHP) and the right to attend the Final Discussion. [PMK 15 Year 2025, Art. 18]

Same as the general provision, which is 5 (five) working days from the delivery of the SPHP. [PMK 15 Year 2025, Art. 18 para 4]

The main basis is internal DGT data (DKP Information System) or external data (ILAP) showing unreported Invoices/Withholding Slips/Assets. [PER-18/PJ/2025, Art. 2]

Yes. For example, proving that the Tax Invoice was actually cancelled or was a transaction not subject to VAT. Rebuttals are submitted when responding to the SPHP. [PMK 15 Year 2025, Art. 18]

Usually no. Document borrowing is limited only to documents relevant to that concrete data (e.g., relevant bank statements, related invoices). [Simple Audit Principle PMK 15/2025]

The Taxpayer can sign the Audit Result Approval Sheet during the SPHP or Final Discussion, so the Tax Assessment Notice (SKP) can be issued immediately. [PMK 15 Year 2025, Art. 18 para 9]

Generally, it is an Underpayment Tax Assessment Notice (SKPKB) or a Tax Collection Notice (STP) if it only relates to administrative sanctions. [PMK 15 Year 2025, Art. 20 para 6]

If related to VAT (unreported Tax Invoices), the sanction imposed can be interest per month (Art. 13 para 2 KUP Law) or a surcharge (Art. 13 para 3) depending on the type of violation. [KUP Law Art. 13]

Yes. If during the examination of Concrete Data other material indications of non-compliance are found requiring in-depth testing (e.g., cost engineering found), the Auditor may propose a repeat/new audit with a Comprehensive type. [Audit Expansion Concept]

Yes, as long as the SPHP has not been delivered. The Taxpayer can disclose the untruth of the act by paying the underpaid tax + penalty sanctions (according to PP 50/2022 rates). [PMK 15 Year 2025, Art. 1 no. 35 (Definition of SPHP as cut-off)]

Yes. The right to file an objection (Art. 25 KUP Law) remains attached to the SKP resulting from a concrete data audit. [KUP Law Art. 25]

The Tax Auditor must cancel the finding in the Final Discussion and propose a Summary LHP or Nil SKP if there are no other corrections. [PMK 15 Year 2025, Art. 20]