A Focused Audit is an audit to test compliance with tax obligations that focuses on one or several specific items (pos) in the Tax Return (SPT) and/or Property Tax Return (SPOP) conducted in depth. [PMK 15 Year 2025, Art. 1 no. 8; Slide Pg. 112]
The difference lies in the scope. A Comprehensive Audit covers all items in the SPT in depth, whereas a Focused Audit is limited to only one or several specific items considered risky, but still audited in depth. [PMK 15 Year 2025, Art. 2 para 2; Slide Pg. 112]
No. Although the scope is limited to certain items, the audit techniques and methods used are in-depth (adjusted to risk), unlike Specific Audits (Pemeriksaan Spesifik) which use simple techniques. [Slide Pg. 112; Transcript Pg. 113]
No, a Focused Audit can cover one, several, or all types of taxes (All Taxes) depending on which items are the focus of the test. [PMK 15 Year 2025, Art. 3 para 1]
PMK 15 of 2025 removes the "Office vs. Field Audit" dichotomy as the primary basis. Focused Audits are categorized by objective and depth, but in practice, the Auditor retains the authority to conduct the audit at the Taxpayer's premises (field) if necessary to deepen the investigation of those items. [Transcript Pg. 106-107; PMK 15 Year 2025 Art. 5 para 4 letter d]
The ToR is a document or written notification detailing the specific items in the SPT, data, and/or specific tax obligations that will be audited by the Tax Auditor. This is a new transparency instrument. [PMK 15 Year 2025, Art. 11 para 2 letter b; Slide Pg. 97]
The Taxpayer is entitled to receive written notification regarding the items checked during the Meeting with the Taxpayer (after the Notice of Audit is delivered). [PMK 15 Year 2025, Art. 11 para 2 letter b]
Yes, but with strict conditions. If during the audit indications are found in other items, the Auditor may change the scope of items. [PMK 15 Year 2025, Art. 11 para 2 letter c]
Yes, but with strict conditions. If during the audit indications are found in other items, the Auditor may change the scope of items. [PMK 15 Year 2025, Art. 11 para 2 letter c]
The Tax Auditor must submit a written notification again to the Taxpayer regarding any changes to the items, data, or obligations being audited. Transparency must be maintained. [PMK 15 Year 2025, Art. 11 para 2 letter c; Slide Pg. 97]
Explicitly, the regulation emphasizes this item notification for Focused Audits. For Comprehensive Audits, the assumption is that all items are audited, so a specific item ToR may not be relevant. [Slide Pg. 98; PMK 15 Year 2025 Art. 11 para 2 letter b]
It provides legal certainty and transparency from the start, so the Taxpayer can prepare documents that are targeted and relevant to the items being tested, without needing to provide unrelated documents. [Transcript Pg. 126]
The testing period is a maximum of 3 (three) months. [PMK 15 Year 2025, Art. 6 para 2 letter b]
It is calculated from the time the Notice of Audit is delivered to the Taxpayer (or representative/proxy/employee). [PMK 15 Year 2025, Art. 6 para 2]
It ends on the date the Notification of Audit Results (SPHP) is delivered to the Taxpayer. [PMK 15 Year 2025, Art. 6 para 2]
A maximum of 30 (thirty) working days calculated from the date the SPHP is delivered until the date of the Audit Report (LHP). [PMK 15 Year 2025, Art. 6 para 3]
Generally, for ordinary reasons, automatic extension (like the old 2 months) is not mentioned. However, extension is possible if related to special conditions (Transfer Pricing/Group). [Analysis of Art. 6 PMK 15 Year 2025]
The testing period can be extended to a maximum of 4 (four) months if the Taxpayer:
Yes. The Tax Auditor is required to conduct a meeting with the Taxpayer after delivering the Notice of Audit to explain the reasons, objectives, and items to be audited (ToR). [PMK 15 Year 2025, Art. 11 para 1]
Yes, the meeting can be conducted face-to-face (offline) or via video conference (online). [PMK 15 Year 2025, Art. 11 para 3]
The results of the meeting are recorded in the Minutes of Meeting signed by the Auditor and the Taxpayer. [PMK 15 Year 2025, Art. 11 para 4]
The Taxpayer must lend books/records/documents within a maximum of 1 (one) month from the date the request letter is delivered. [PMK 15 Year 2025, Art. 12 para 5]
Yes, it is mandatory. The Tax Auditor must convey interim results and provide an opportunity for the Taxpayer to attend the Discussion of Interim Findings. [PMK 15 Year 2025, Art. 17 para 1; Slide Pg. 92]
At the latest 1 (one) month before the testing period ends (before the end of the 3rd month). [PMK 15 Year 2025, Art. 17 para 3]
The Taxpayer is entitled to an explanation, but the authority to expand items lies with the Auditor as long as written notification of the change is delivered. The Taxpayer may refute findings on these new items during the PTS or Final Discussion. [PMK 15 Year 2025, Art. 11 para 2 letter c]
The Taxpayer may state a refusal, but the Auditor will create a Minutes of Audit Refusal. If refused, the tax may be calculated officially (ex officio) and the Taxpayer may be subject to criminal/administrative sanctions. [PMK 15 Year 2025, Art. 15; Art. 13]
The Taxpayer has the right to request a discussion with the Audit Quality Assurance Team if there is a legal basis for correction that has not been agreed upon during the Final Discussion. [PMK 15 Year 2025, Art. 19 para 1 letter f]
Yes, the Auditor has the authority to access and download electronic data. The Taxpayer is obliged to provide such access. [PMK 15 Year 2025, Art. 7 para 4 letter b]
The Auditor may determine taxable income officially (ex officio) and issue an Underpayment Tax Assessment Notice plus administrative sanctions. [PMK 15 Year 2025, Art. 20 para 12]
Yes. Documents not submitted during the initial lending may be submitted at the latest before the Minutes of Final Discussion of Audit Results are signed. [PMK 15 Year 2025, Art. 12 para 11]
The final product is a Tax Assessment Notice (SKP) (Underpayment, Nil, or Overpayment) and/or a Tax Collection Notice (STP). [PMK 15 Year 2025, Art. 20 para 6]
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