Ekualisasi PPh 23, SPT PPh Badan, SPT Masa Unifikasi, Dasar Pengenaan Pajak, Objek PPh Pasal 23, PPN Masukan, Biaya Jasa dan Sewa, Rekonsiliasi Fiskal, Kertas Kerja Pemeriksaan, Bukti Potong

In the framework of tax supervision and audit in Indonesia, specifically under the regime of Minister of Finance Regulation Number 15 of 2025, data validity is the main pillar. One of the testing techniques most frequently used by Tax Auditors to test third-party withholding tax compliance is Equalization.

The focus of this discussion is the technical equalization technique between expense accounts in the Financial Statements (Corporate Income Tax/CIT Return) and the Tax Base (DPP) of PPh Article 23 (Income Tax Art. 23) reported in the Unified Periodic Tax Return cumulatively for one tax year. This technique is technically regulated in SE-65/PJ/2013 concerning Guidelines for the Use of Audit Methods and Techniques and various technical modules of the Directorate General of Taxes (DGT).

Urgency and Basic Concept of PPh Article 23 Equalization

PPh Article 23 Equalization is an analytical procedure to ensure that all payments for services, rentals, dividends, interest, and royalties expensed by the company have been withheld according to the applicable rates (2% or 15%).

Fundamentally, this audit bridges two different recording bases:

The discrepancy between these two figures—without adequate reconciliation—is a risk indicator (red flag) for Tax Auditors that there is potential unpaid tax.

Stage 1: Financial Statement Account Mapping

The audit procedure begins with dissecting the Taxpayer's Financial Statements. Based on the Profit and Loss Audit Program, the Auditor will map General Ledger (GL) accounts that are naturally PPh Article 23 objects.

The main target accounts include:

• Rent Expenses: Heavy equipment rent, vehicle rent, machinery rent (except land/building rent which falls under Final Tax).
• Service Expenses: Technical services, management services, consulting services, legal services, maintenance/repair services, outsourcing services, waste management services, etc.
• Interest Expenses: Loan interest to non-bank business entities.
• Dividends: Dividend payments to Domestic Corporate Taxpayers (note: post-Job Creation Law, certain dividends may be exempt, but remain equalization objects for validation).
• Miscellaneous Expenses: Often a "hiding place" for small service costs that escape withholding.

Stage 2: Technical Equalization Calculation Procedure

Referring to the standard audit working papers in SE-08/PJ/2012 and guidelines in SE-65/PJ/2013, here are the technical steps taken by the Auditor:

A. Calculating Total Objects According to Corporate CIT

The Auditor sums up the expense account balances mapped above from the Profit and Loss Statement.

Initial Formula: Total Rent Expenses + Total Service Expenses + Interest + Royalties.

B. Adjustment Variables

The CIT figure must be adjusted with the following variables to obtain the "PPh 23 Objects that Should be Withheld" figure:

1. Additions:
   • Capitalized Expenses: Services or interest capitalized into the value of fixed assets. These do not appear in the P&L but are liable for PPh 23.
   • Down Payments: Down payments for services/rentals recorded on the Balance Sheet as Prepaid Expenses. PPh 23 is due upon down payment, not upon amortization.
2. Deductions:
   • Material/Goods Purchases: In service bills, service values and material values are often mixed. Materials are not PPh 23 objects if separated in the invoice.
   • Reimbursement: If third-party invoices are attached and there is no mark-up, reimbursement is not a PPh 23 object.
   • Payments to Exempted Parties: For example, interest payments to Banks, or rental payments to Taxpayers with a Certificate of Exemption (SKB).
   • Timing Differences (Accruals): Expenses recognized conceptually (accrued) at year-end but payment is not yet due.

C. Comparison with Unified Periodic Return

The calculated figure above is compared with the accumulated Gross Income listed in the PPh Article 23 Withholding Slips from January to December.

Difference (Correction) = DPP According to Auditor - DPP Reported in Periodic Return.

Stage 3: Cross-Check with Input VAT

One of the most sophisticated techniques emphasized in audit training materials is Equalization of PPh 23 Objects with Input VAT. Logikanya sederhana namun mematikan: If a Taxpayer credits Input Tax Invoices for the acquisition of Taxable Services (JKP) or Rentals, then automatically the transaction is a PPh Article 23 object.

Procedure:

1. The Auditor pulls Input Tax Invoice data from the system.
2. Filters service/rental transactions.
3. The Tax Base (DPP) on the Input Tax Invoice is compared with the reported PPh 23 Tax Base.
4. If there is an Input Tax Invoice for services credited, but no PPh 23 withholding slip issued, the Auditor will establish a positive correction.

Common Disputes and Mitigation

In the final discussion of audit results, Taxpayers often face these equalization findings. Here are the main issues and how to resolve them:

Legal Products and Sanctions

If the difference cannot be explained, the Auditor will issue an Underpayment Tax Assessment Notice (SKPKB) for PPh Article 23. In addition to the principal tax (2% or 15%), the Taxpayer will be subject to administrative sanctions in the form of interest.

Under PMK 15 of 2025, this finding can trigger an expanded audit to test the validity of those costs in CIT (deductibility), especially if the counterparty is unclear.

Conclusion

PPh Article 23 Equalization is not merely matching final figures, but testing the consistency of transaction flows. The best strategy is to perform self-equalization monthly. Ensure every service/rent expense has a Withholding Slip reference, and every Input VAT crediting for Services is followed by a PPh 23 Withholding Slip.

Reference Sources:

• • [PMK 15 Year 2025] - Procedures for Tax Audit.
• • [SE-65/PJ/2013] - Guidelines for the Use of Audit Methods and Techniques.
• • [Bahan Ajar DJP] - Equalization formula for Corporate CIT items and Withholding Tax Objects.
• • [SE-08/PJ/2012] - Audit Working Paper Format (KKP) for PPh Article 23.
• • [Modul Ringkas Tahapan Pemeriksaan Pajak] - Tax Credit Testing and Equalization.