Ekualisasi Pajak, PPN Masukan, PPh Pasal 23, PPh Pasal 26, PPN Jasa Luar Negeri, Objek Pemotongan, Rekonsiliasi Fiskal, Faktur Pajak, Kertas Kerja Pemeriksaan, PMK Nomor 15 Tahun 2025

In the modern tax audit architecture in Indonesia, as reinforced in Minister of Finance Regulation Number 15 of 2025 regarding Tax Audit Procedures, the audit approach is no longer conducted in silos. Tax Auditors now apply a fully integrated "All Taxes" testing approach. One of the most sophisticated and lethal testing methods for Taxpayers with disorderly administration is Cross-Equalization.

This article will comprehensively dissect the technical procedure of equalization between the Tax Base (DPP) of Income Tax Article 21, 23, 4 paragraph (2), and 26 with the Tax Base (DPP) of Input VAT and VAT on Offshore Services (PPN JLN) credited/paid in the Periodic VAT Return cumulatively for one tax year. This discussion refers to SE-65/PJ/2013 on Guidelines for the Use of Audit Methods and Techniques, as well as internal technical modules of the Directorate General of Taxes (DGT).

Basic Concept: The Compliance Triangle of VAT and Withholding Tax

This equalization is based on the logic of the close transactional relationship between the consumption of Services/Rentals and the tax withholding obligation.

1. VAT Side (Input Tax): When a company pays for Taxable Services (JKP) or Rentals to a Taxable Entrepreneur (PKP), the company will receive an Input Tax Invoice and credit it in the Periodic VAT Return (Form 1111 B2) or pay VAT on Offshore Services (Form 1111 B1).
2. Income Tax Side (Withholding): For the same service/rental payment, the company is obliged to withhold PPh Article 23 (Corporate), PPh Article 21 (Individual), PPh Article 4(2) (Construction/Land & Building Rent), or PPh Article 26 (Non-Resident Taxpayer).

If a Taxpayer credits Input VAT on services (claiming expenses) but does not report the PPh withholding (no withholding slip), this is a strong indicator of non-compliance (red flag). The Auditor will use the DPP on the Input Tax Invoice as a basis to calculate the Underpaid Income Tax.

Stage 1: Data Collection and VAT Segregation

The first step in the audit procedure is to dissect the Periodic VAT Return. The Auditor does not look at the total Input VAT in aggregate but performs segregation based on transaction types:

A. Analysis of Form 1111 B2 (Domestic Input Tax)

The Auditor will download the Input Tax Invoice details and filter them:

• Filter 1: Exclude Taxable Goods (BKP) purchase transactions. Goods purchases (except certain imports) are generally not objects of Withholding Tax.
• Filter 2: Identify Taxable Service (JKP) transactions. Keywords like "Service", "Rent", "Maintenance", "Repair", "Management Fee", or "Handling" will be flagged.
• Filter 3: Identify Land/Building Rent and Construction transactions.

B. Analysis of Form 1111 B1 (Imports and Offshore Services)

The Auditor separates Goods Imports (PIB documents) from Utilization of JKP from Outside the Customs Area (Offshore VAT SSP). Utilization of offshore services is the main target for PPh Article 26 equalization.

Stage 2: Technical Equalization Procedure per Tax Type

Based on guidelines SE-65/PJ/2013 and SE-08/PJ/2012, here are the equalization working papers constructed by the Auditor:

1. Equalization of PPh Article 23 and PPh Article 21 (Domestic Vendors)

The Auditor compares the Service DPP on the Input Tax Invoice with the DPP on the PPh 23/21 Withholding Slip.

Audit Logic: If PT A credits Input VAT from PT B for "Machine Maintenance Services" worth IDR 100 Million, then PT A must issue a PPh Article 23 Withholding Slip in the name of PT B with a DPP of IDR 100 Million.

1. Pull Input VAT data (B2) from the counterparty (Vendor).
2. Pull PPh 23/21 Withholding Slip data for the same Vendor.
3. Calculate the difference:
   • If VAT DPP > PPh 23 DPP: Indication of under-withheld PPh 23.
   • If PPh 23 DPP > VAT DPP: Indication of purchasing services from Non-PKP or missed Tax Invoice.

2. Equalization of PPh Article 4 paragraph (2) (Construction and Rent)

• Identify Input Tax Invoices from construction or property companies.
• Juxtapose with the reporting of Periodic Final Income Tax Article 4(2).
• Risk Analysis: Reclassification to Final PPh 4(2) if the provider holds a Construction Business Certificate (SBU).

3. Equalization of PPh Article 26 with VAT on Offshore Services

Stage 3: Reconciliation and Discrepancy Variables

In the Final Audit Discussion, the Taxpayer is given the opportunity to refute via valid variables:

A. Timing Difference

• VAT Crediting: Tax Invoices can be credited within 3 tax periods.
• PPh Liability Timing: Due at month-end of payment or accrual.
• Solution: Provide a "Timing Difference Reconciliation Table".

B. Down Payment, C. Exchange Rate, & D. Non-PPh Object

Differences often arise from cash flow vs accrual recording, KMK rate date differences for PPh 26, or pure cost reimbursements that are VAT-able but not withholding objects.

Legal Implications and Sanctions

Based on SE-15/PJ/2018, findings can lead to:

• SKPKB PPh Potput: Underpaid principal + interest.
• SKPKB PPN: For unpaid Offshore VAT.
• Deductibility Test: Questioning validity of expenses in Corporate CIT.

Conclusion and Professional Recommendation

Data inconsistencies are hard to refute in the Coretax era without neat documentation.

1. Payment SOP Integration: Ensure PPh is calculated before processing vendor bills.
2. Review Input Tax Invoices: Match DPP values before crediting.
3. Reconcile Offshore VAT and PPh 26: One-on-one pairing for audit readiness.
4. Document Archive: Keep contracts separating materials and services.

Reference Sources:

• [PMK 15 Year 2025] - Procedures for Tax Audit.
• [SE-65/PJ/2013] - Guidelines for the Use of Audit Methods and Techniques.
• [SE-08/PJ/2012] - Guidelines for Compiling Audit Working Papers.
• [SE-15/PJ/2018] - Audit Policy and Risk Analysis.