An Audit is a series of activities to collect and process data, information, and/or evidence carried out objectively and professionally based on an auditing standard to test compliance with the fulfillment of tax obligations and/or for other purposes. [Article 1 point 6]
A Comprehensive Audit is an Audit to test compliance with the fulfillment of tax obligations covering all items in the Tax Return (SPT) and/or the Object of Tax Notification (SPOP) in depth. [Article 1 point 7]
A Focused Audit is an Audit to test compliance focused on one or several items in the Tax Return (SPT) and/or the Object of Tax Notification (SPOP) in depth. [Article 1 point 8]
A Specific Audit is an Audit to test compliance carried out specifically on one or several items in the Tax Return (SPT), data, or certain tax obligations in a simple manner. [Article 1 point 9]
Electronic Data is data in electronic form which is not limited to writing, sound, images, maps, designs, photos, EDI (Electronic Data Interchange), electronic mail (e-mail), telegrams, telexes, telecopies, letters, marks, numbers, access codes, symbols, or perforations. [Article 1 point 32]
A discussion between the Taxpayer and the Tax Auditor regarding the preliminary audit findings, the results of which are recorded in a minute of meeting. [Article 1 point 34]
A team formed by the Director General of Taxes to discuss Audit results limited to the legal basis of corrections not yet agreed upon between the Auditor and the Taxpayer during the Final Discussion of Audit Results. [Article 1 point 37]
A report containing the termination of an Audit without a proposal for the issuance of a Tax Assessment Letter (SKP). [Article 1 point 39]
An Audit conducted on a Taxpayer for whom a Tax Assessment Letter (SKP) has been issued based on the results of a previous Audit for the same type of tax and tax period/year. [Article 1 point 41]
A civil servant within the Directorate General of Taxes (DGT) or an expert appointed by the Director General of Taxes who is given the task, authority, and responsibility to carry out Audits. [Article 1 point 27]
A regular recording process to collect financial data (assets, liabilities, equity, income, costs) closed by preparing financial statements (Balance Sheet & Profit and Loss Statement). [Article 1 point 31]
A Representative is a person who represents the Taxpayer (e.g., Management/Board of Directors for an Entity) in accordance with the Law on General Provisions and Tax Procedures (UU KUP). [Article 1 point 20]
A person who receives a special power of attorney from the Taxpayer in accordance with tax provisions. [Article 1 point 19]
A letter issued by the Head of the Tax Office (KPP) as a notification that the PBB Object and its Taxpayer have been registered in the DGT system. [Article 1 point 24]
To test compliance with the fulfillment of tax obligations and for other purposes in the context of implementing the provisions of tax laws and regulations. [Article 2 paragraph 1]
Comprehensive Audit, Focused Audit, and Specific Audit. [Article 2 paragraph 2]
Yes, the scope of the audit includes Carbon Tax. [Article 3 paragraph 2 letter g]
Yes, an audit may cover one, several, or all types of taxes, for one or several Tax Periods, Fractions of a Tax Year, or Tax Years, including one or several PBB Tax Objects. [Article 3 paragraph 1]
Yes, it is one of the audit criteria to test compliance. [Article 4 paragraph 1 letter a]
Yes, submitting a Tax Return (SPT) declaring a loss is a criterion for an audit to test compliance. [Article 4 paragraph 1 letter c]
Yes, conducting a merger, consolidation, expansion, liquidation, dissolution, or planning to leave Indonesia forever are criteria for an audit to test compliance. [Article 4 paragraph 1 letter h]
Yes, changing the bookkeeping method is included in the audit criteria to test compliance. [Article 4 paragraph 1 letters e and f]
Taxpayers selected for an Audit based on compliance risk analysis (Risk-Based Taxpayer). [Article 4 paragraph 1 letter j]
An Audit caused by the existence of concrete data indicating that the tax due has not been paid or has been underpaid. [Article 4 paragraph 1 letter l]
A tax invoice that has obtained approval from the DGT system but has not/was not reported by the Taxpayer in the VAT (PPN) Period Tax Return. [Article 4 paragraph 2 letter a]
An Income Tax (PPh) withholding/collection slip that has not/was not reported by the issuer in the PPh Period Tax Return. [Article 4 paragraph 2 letter b]
It is followed up through simple testing (Specific Audit). [Article 4 paragraph 2]
If there are indications that the amount of PBB due based on data/analysis is greater than that calculated based on the SPOP submitted by the Taxpayer. [Article 4 paragraph 1 letter n]
In principle, an Audit for Other Purposes is a series of activities to collect and process data, information, and/or evidence carried out objectively and professionally based on auditing standards, conducted in the context of implementing provisions of tax laws and regulations (administrative or procedural in nature), and not primarily aimed at calculating underpaid tax (testing compliance). [Article 1 point 6 jo. Article 2 paragraph (1)]
The primary objective is to obtain the data or conclusions necessary for implementing certain tax laws and regulations, such as the issuance of administrative decisions, approval of facilities, or fulfillment of international cooperation, other than the purpose of calculating the amount of tax due. [Article 2 paragraph (1)]
Based on PMK 15 of 2025, Audit for Other Purposes has activities that can be in the form of:
This audit is conducted if the Taxpayer meets certain criteria, including:
An Audit for Other Purposes must be completed within a maximum period of 4 (four) months. This time is calculated from the date the Audit Notification Letter is delivered to the Taxpayer until the date of the Audit Result Report (LHP). [Article 6 paragraph (8)]
Unlike a compliance audit which results in a Tax Assessment Letter (SKP), the result of an Audit for Other Purposes is a follow-up proposal appropriate to its audit criteria. Example: If the purpose is NPWP deletion, the result is a recommendation/decision that the NPWP deletion request is accepted or rejected. [Article 20 paragraph (6) letter b]
A Taxpayer may refuse (by signing a statement of refusal or a minute of refusal). However, such refusal will be the basis for the Director General of Taxes to make a decision or consideration in accordance with the audit purpose. Example: If you refuse to be audited when applying for NPWP deletion, then the deletion request may be rejected. [Article 15 paragraph (5)]
Yes, the resolution of an APA application is included in the criteria for an Audit for Other Purposes. [Article 4 paragraph 3 letter r]
Yes, the resolution of a Mutual Agreement Procedure is included in the criteria for an Audit for Other Purposes. [Article 4 paragraph 3 letter q]
Yes, the determination of costs at the exploration stage is a criterion for an Audit for Other Purposes. [Article 4 paragraph 3 letter t]
Yes, the fulfillment of exchange of information based on international agreements (Tax Treaty) is a criterion for an Audit for Other Purposes. [Article 4 paragraph 3 letter p]
Yes, it is included in the criteria for an Audit for Other Purposes. [Article 4 paragraph 3 letter b]
Yes, the determination of a Taxpayer located in a remote area is a criterion for an Audit for Other Purposes. [Article 4 paragraph 3 letter j]
Yes, the resolution of objections is included in the criteria for an Audit for Other Purposes. [Article 4 paragraph 3 letter g]
Yes, the implementation of physical inspection in the context of providing an endorsement from another place within the customs area to a free trade zone and free port is included in the criteria for an Audit for Other Purposes. [Article 4 paragraph 3 letter u]
A physical inspection in the context of providing an endorsement from another place within the customs area to a free trade zone and free port. [Article 4 paragraph 3 letter u]
No, the audit timeframe for Oil & Gas PSC Cost Recovery is excluded from this rule and follows a separate Ministerial Regulation. [Article 6 paragraph 10]
Based on Article 6 paragraph (5), the reasons for extending the testing period are limitatively restricted only to: (1) group Taxpayers, (2) transfer pricing indications, and (3) financial transaction engineering indications. This PMK does not mention technical system disruption as a reason for extending the testing period. [Article 6 paragraph 5]
Yes, the reason for extension (e.g., transfer pricing) must be stated in the letter format. [Annex Letter A, Number 19]
The official at the Audit Implementation Unit must deliver a Notification of Testing Period Extension in writing to the Taxpayer. [Article 6 paragraph 7]
The letter must contain the reason for extension (e.g., transfer pricing indications or group Taxpayer) and the duration of the extension (in months). [Annex Letter A]
There is no regulation regarding the right to refuse an extension (as this is an official authority), but the Taxpayer has the right to receive a written Notification of Testing Period Extension. [Article 6 paragraph 7]
Yes, in the standard form, there is a "Received by" column which must be filled with the name, position, date, signature, and company stamp of the Taxpayer. [Annex Letter A]
The Audit Standards include 3 (three) main parts:
Tax Auditors must meet the following requirements:
In conducting an audit, the Auditor must:
In conducting an audit, the Auditor must:
At the DGT office, the Taxpayer's residence/domicile, place of business, PBB Object location, or other places deemed necessary. [Article 5 paragraph 4 letter d]
The Tax Auditor is obliged to base Audit findings on strong and relevant evidence and based on the provisions of tax laws and regulations. Findings not based on strong evidence are potentially cancelable through the QA mechanism or objection. [Article 5 paragraph 4 letter c]
Yes. Audit Implementation Standards require the documentation of audit implementation in the form of Audit Working Papers (KKP), which then become the basis for preparing the LHP. [Article 5 paragraph 4 letter e & paragraph 5 letter a]
The LHP is prepared based on the Audit Working Papers (KKP). [Article 5 paragraph 5 letter a]
The implementation of the Audit, conclusions, and the Tax Auditor's proposal. [Article 5 paragraph 5 letter b]
Yes, according to Reporting Standards, the LHP must be prepared based on Audit Working Papers (KKP). The LHP must contain the implementation, conclusions, and the Tax Auditor's proposal. [Article 5 paragraph 5]
Yes, a Tax Auditor shall not be sanctioned as long as the audit was conducted in accordance with Audit Standards, and carried out based on good faith and in accordance with the provisions of laws and regulations. [Article 29]
The Taxpayer may submit an application for discussion with the Audit Quality Assurance (QA) Team.
The testing period and the period for the Final Discussion of Audit Results & reporting. [Article 6 paragraph 1]
A maximum of 5 (five) months. [Article 6 paragraph 2 letter a]
A maximum of 3 (three) months. [Article 6 paragraph 2 letter b]
A maximum of 1 (one) month. [Article 6 paragraph 2 letter c]
It is calculated from the date the Audit Notification Letter is delivered to the Taxpayer, Representative, Proxy, or the representing party. [Article 6 paragraph 2]
A maximum of 30 (thirty) working days. [Article 6 paragraph 3]
A maximum of 10 (ten) working days. [Article 6 paragraph 4 letter a]
A maximum of 10 (ten) working days. [Article 6 paragraph 4 letter b]
Yes, it can be extended for a maximum of 4 (four) months for certain conditions. [Article 6 paragraph 5]
Related to a group Taxpayer, indications of transfer pricing, or financial transaction engineering. [Article 6 paragraph 5]
A maximum of 4 (four) months. [Article 6 paragraph 8]
Yes, audits of PSC Cost Recovery follow the provisions of a separate Ministerial Regulation. [Article 6 paragraph 10]
If it relates to a Taxpayer in a group, indicated transfer pricing, or special transactions with indications of financial engineering (maximum extension of 4 months). [Article 6 paragraph 5]
A collection of two or more Taxpayers, both Entities and individuals, in a business group consisting of parties having a special relationship in accordance with the provisions of tax laws and regulations. [Article 6 paragraph 6]
It is not automatic. The phrase used is "a maximum of 4 (four) months", meaning the Auditor may extend it for less than 4 months according to the needs of the testing complexity. [Article 6 paragraph 5]
The existence of indications of other special transactions indicated to involve financial engineering. [Article 6 paragraph 5 letter b]
PMK 15 of 2025 does not provide a lexical definition but places it as part of "other special transactions" whose complexity is equivalent to Transfer Pricing. Indications of financial engineering are a valid reason for the Auditor to extend the testing period to explore the transaction scheme. [Article 6 paragraph 5 letter b]
The testing period can be extended for a maximum period of 4 (four) months. [Article 6 paragraph 5]
The rule uses the phrase "indicated" (indicated to be performing a transaction...), which means the Auditor only needs a strong initial indication of financial transaction engineering to be able to apply for a time extension for further proof. [Article 6 paragraph 5 letter b]
The Tax Auditor is authorized to extend the testing period for a maximum period of 4 (four) months. This is done to provide sufficient time for the Auditor to dissect the special transaction scheme. [Article 6 paragraph 5 letter b]
The Auditor, through the Head of the Audit Implementation Unit, must deliver a Notification Letter of Testing Period Extension to the Taxpayer, specifically stating the reason "there are indications of other special transactions indicated to involve financial engineering" on the form. [Article 6 paragraph 7; Annex Letter A Number 19]
Yes, in the letter format (Annex A number 19), the Auditor is obliged to fill in the reason for the testing period extension (e.g., "indicated to be performing transfer pricing transactions"). [Annex Letter A]
Regulatedly, a Concrete Data Specific Audit has a strict time of 10 working days. If complex indications like transfer pricing are found, the audit mechanism will usually be upgraded or its type changed (e.g., to a Comprehensive Audit) through a Revised Audit Order (SP2 Perubahan) to allow for a time extension, because Article 6 paragraph 5 refers to the general testing period (paragraph 1a). [Article 6 paragraphs 4 and 5; Systematic Interpretation of Article 9 paragraph 2 regarding SP2 Perubahan]
Regulatedly, a Concrete Data Specific Audit has a strict time of 10 working days. If complex indications like transfer pricing are found, the audit mechanism will usually be upgraded or its type changed (e.g., to a Comprehensive Audit) through a Revised Audit Order (SP2 Perubahan) to allow for a time extension, because Article 6 paragraph 5 refers to the general testing period (paragraph 1a). [Article 6 paragraphs 4 and 5; Systematic Interpretation of Article 9 paragraph 2 regarding SP2 Perubahan]
The Tax Auditor Identification Card and the Audit Order (SP2). [Article 7 paragraph 1 letter a]
The outer face is dark blue with gold lettering; the inner face has a white base color. [Annex Letter B, Filling Instructions]
Yes, the Auditor is obliged to provide an explanation regarding the reason and purpose of the Audit. [Article 7 paragraph 2 letter a]
To conduct a Discussion of Preliminary Findings (except for a Concrete Data Specific Audit). [Article 7 paragraph 2 letter e & paragraph 3]
To access and/or download Electronic Data related to the purpose of the Audit. [Article 7 paragraph 4 letter b]
Yes, the Auditor is authorized to perform the Sealing of a place/room/item. [Article 7 paragraph 4 letter f]
Yes, they can. If books, records, and documents (including electronic data) need their confidentiality protected, the Taxpayer may submit a request that the audit be conducted at the Taxpayer's premises by providing a special room. [Article 12 paragraph 10; Article 7 paragraph 4 letter g point 3]
Yes. The Auditor is authorized to request the Taxpayer's assistance to provide personnel and/or equipment (such as a computer or server) at the Taxpayer's expense if accessing Electronic Data requires special equipment and/or expertise. [Article 7 paragraph 4 letter g point 1; Article 8 paragraph 4 letter d]
They have the right to ask the Auditor to show the letter of change of the Tax Audit team. [Article 8 paragraph 1 letter c]
Yes, the Auditor is obliged to deliver a written notification regarding the items in the Tax Return, data, and/or certain tax obligations being audited (including if there is a change in items). [Article 7 paragraph 2 letters c & d]
Yes, they have the right in accordance with Article 8 paragraph (4) of the UU KUP. [Article 8 paragraph 2 letter a]
Yes, they have the right to attend the Final Discussion of Audit Results. [Article 8 paragraph 2 letter h]
If there are still differences of opinion on the legal basis of corrections during the Final Discussion. [Article 8 paragraph 2 letter i]
To show/lend books, records, and documents that form the basis of the bookkeeping. [Article 8 paragraph 4 letter a]
To provide the opportunity to access/download and provide personnel/equipment if special expertise is needed. [Article 8 paragraph 4 letters b & d]
If indications of a criminal act are found and followed up with a Preliminary Evidence Audit (Bukper) or Investigation. [Article 23 paragraph 1]
Yes, through a notification letter that the audit is suspended. [Article 23 paragraph 3]
Returned to the Taxpayer. [Article 23 paragraph 5]
If the Bukper/Investigation is terminated or there is an acquittal/dismissal court decision. [Article 23 paragraph 6]
Insufficient evidence, not a criminal act, ne bis in idem, or the suspect dies. [Article 23 paragraph 6 letter b]
No, the audit only tests data other than that disclosed in Article 8 paragraph (3) (Disclosure during Bukper) or Article 44B (Fines during Investigation). [Article 23 paragraph 14]
If the WP performs disclosure of inaccuracy of acts (Article 8 paragraph 3) or settlement (Article 44B). [Article 23 paragraph 7]
A maximum of 5 working days after the termination of Bukper/Investigation. [Article 23 paragraph 9]
Not allowed, until the Bukper is finished. [Article 24 paragraph 1]
A Re-audit is an audit performed on a Taxpayer for whom a Tax Assessment Letter (SKP) or a PBB SKP has been issued based on the results of a previous audit for the same type of tax and tax period/year. [Article 1 point 41]
A Re-audit can only be performed if there is:
Based on this PMK, a Re-audit can be performed if there is new data including data previously not revealed. This data must be data that has never been disclosed or was not known by the fiskus at the time of the previous audit, which if taken into account would result in the tax due becoming larger. [Article 25 paragraph 1 letter a]
Yes, it can. A Re-audit can be performed based on written information from the Taxpayer of their own volition (in accordance with Article 15 paragraph 3 of the UU KUP), even if there are no new data findings from the fiskus side directly. [Article 25 paragraph 1 letter b]
If it results in additional tax, the legal product issued is an Additional Tax Underpayment Assessment Letter (SKPKBT). [Article 25 paragraph 2]
If the PBB Re-audit result results in an additional amount of tax due, then a PBB Tax Assessment Letter (SKP PBB) is issued. [Article 25 paragraph 3]
The Re-audit is terminated by creating a Summary Audit Result Report (LHP Sumir), and the Taxpayer will be notified regarding the termination. [Article 25 paragraph 4; Article 20 paragraph 9 letter c]
Terminated with a Summary LHP. [Article 25 paragraph 4]
Yes. If a Re-audit does not increase tax due but changes the amount of fiscal loss, the Director General of Taxes issues a Decision Regarding Fiscal Loss. [Article 25 paragraph 5]
The decision is used as a legal basis to account for (compensate) fiscal loss to the next tax year. [Article 25 paragraph 6]
Uses the format of the Decision on Fiscal Loss Determination Based on Re-audit as listed in Annex Letter QQ. [Article 28 letter qq; Annex Letter QQ]
Yes, the Auditor is obliged to deliver a Notification Letter of Audit Termination. In the letter, the reason for termination is stated, for example "The Re-audit did not result in an addition to the amount of tax". [Article 20 paragraph 9 letter c; Annex Letter PP Number 19]
It can. Article 25 paragraph (3) explicitly mentions a PBB Re-audit can be performed on a Tax Object for which a Nil SKP has previously been issued, as long as there is new data/novum. [Article 25 paragraph 3]
The document details:
Electronic, direct, or post/expedition service. [Article 27 paragraph 1]
Electronic, direct, or facsimile. [Article 27 paragraph 2]
Electronic signature. [Article 27 paragraph 4]
Annex Letter A. [Article 28 letter a]
Annex Letter B. [Article 28 letter b]
Annex Letter C. [Article 28 letter c]
Annex Letter F. [Article 28 letter f]
Annex Letter G. [Article 28 letter g]
Annex Letter K. [Article 28 letter k]
Annex Letter M. [Article 28 letter m]
Annex Letter N. [Article 28 letter n]
Annex Letter P. [Article 28 letter p]
Annex Letter T. [Article 28 letter t]
Annex Letter X. [Article 28 letter x]
Annex Letter Z. [Article 28 letter z]
Annex Letter AA. [Article 28 letter aa]
Annex Letter BB. [Article 28 letter bb]
Annex Letter DD. [Article 28 letter dd]
Annex Letter EE. [Article 28 letter ee]
Annex Letter GG. [Article 28 letter gg]
Annex Letter HH. [Article 28 letter hh]
Annex Letter KK. [Article 28 letter kk]
Annex Letter MM. [Article 28 letter mm]
Annex Letter NN. [Article 28 letter nn]
Annex Letter PP. [Article 28 letter pp]
Annex Letter QQ. [Article 28 letter qq]
Based on an Audit Order (SP2). [Article 9 paragraph 1]
The names of the audit team, Taxpayer's identity, tax period/year, purpose, criteria, and scope of the audit. [Annex Letter C]
Yes, it states the type of audit (Comprehensive, Focused, or Specific). [Annex Letter F, Number 22
It can be delivered to a Proxy, employee, or adult family member. [Article 10 paragraph 2]
The audit can still be conducted and the letter can be delivered to:
The Tax Auditor will ask them to sign a Statement of Refusal to Assist the Smooth Running of the Audit. If they refuse to sign the statement, the Auditor will create a Minute of Refusal to Assist the Smooth Running of the Audit. [Article 10 paragraphs 10 & 11; Annex Letters G & H]
The date of delivery of the Audit Notification Letter. [Article 10 paragraph 6]
No, the Taxpayer cannot amend the Tax Return after the Audit Notification Letter has been delivered. [Article 10 paragraph 7]
The Taxpayer is deemed to have refused the Audit. [Article 10 paragraph 9]
Yes, the Audit Team may be assisted by one or more persons who have certain expertise (Expert), originating from either within the DGT or from outside the DGT (e.g., IT experts, appraisers, or geologists). [Article 9 paragraph 3]
The Expert must be equipped with an Assignment Letter to Assist the Audit Implementation signed by the Head of the Audit Implementation Unit. [Annex Letter E]
Annex Letter E. [Article 28 letter e]
Yes, in the implementation of an Audit, a valuation for tax purposes can be conducted in accordance with the provisions of laws and regulations. [Article 26]
The Head of the Audit Implementation Unit must issue a Revised Audit Order, and the Auditor is obliged to show the letter to the Taxpayer. [Article 9 paragraph 2; Article 7 paragraph 1 letter c; Annex Letter D]
After the delivery of the Audit Notification Letter. [Article 11 paragraph 1]
No, attendance cannot be proxied, but the Taxpayer may be accompanied by parties who understand the business activities. [Annex Letter I]
Yes, it can be via video conference. [Article 11 paragraph 3 letter b]
The Auditor creates the minutes and delivers them to the Taxpayer. The Taxpayer then signs and delivers them back to the Auditor. [Article 11 paragraphs 5 & 6]
A maximum of 5 (five) working days calculated from the date the minutes are delivered by the Auditor. [Article 11 paragraph 6]
The Taxpayer is deemed to have refused to sign the minutes of the meeting results. [Article 11 paragraph 7 letter b]
The signing is done electronically (electronic signature). [Article 27 paragraph 4]
The signing is performed using an ordinary (wet) signature. [Article 27 paragraph 5]
The procedure is that the signature is performed first by the Taxpayer, then by the Audit Team. [Article 27 paragraph 5]
They are valid and binding, the procedures for which follow the Ministerial Regulation regarding the core tax administration system (Coretax). [Article 27 paragraphs 3 & 4]
Excluded, the explanation is delivered in writing together with the Audit Notification Letter. [Article 11 paragraphs 9 & 10]
A list of the types/names of books, records, and/or documents that must be lent. [Annex Letter K]
A maximum of 1 (one) month since the request letter was delivered. [Article 12 paragraph 2]
A maximum of 2 times (Warning I and Warning II). [Annex Letter M]
After 2 (two) weeks from the date the request letter was delivered. [Article 12 paragraph 5 letter a]
The Second Warning Letter is issued after 3 (three) weeks from the date of delivery of the request letter for document/book lending (if the first warning is not fulfilled). [Article 12 paragraph 5 letter b]
They are deemed not to have been provided at the time of the Audit. [Article 12 paragraph 4]
The Taxpayer is obliged to state that the document conforms to the original. [Article 12 paragraph 6]
They can be submitted until before the minutes of the Final Discussion of Audit Results (PAHP) are signed. [Article 12 paragraph 11]
Taxable income may be calculated ex-officio. [Article 12 paragraph 14]
Limited to documents related to the calculation of business turnover/gross (to calculate net income) and tax credit documents. [Article 18 paragraph 12]
The Tax Auditor is obliged to return the lent books/records/documents. This return must be accompanied by the creation of a Receipt for Return of Books, Records, and/or Documents signed by both parties. [Article 12 paragraph 8; Annex Letter O]
If the Taxpayer does not provide the opportunity to enter a place, refuses to provide data access assistance, or is not present. [Article 14 paragraph 2]
Yes, the Auditor may request assistance from the Indonesian National Police and/or the local regional government in the context of sealing or unsealing. [Article 14 paragraph 10]
? It is elongated in shape measuring 30 x 10 cm, white paper color, red "DISEGEL" (SEALED) text, and a faint background Ministry of Finance logo. [Annex Letter P]
A sticker with perforations, which if pasted and opened will be damaged or torn. [Annex Letter P, Filling Instructions]
"Whoever intentionally breaks, discards, or damages this seal is threatened with imprisonment for a maximum of 2 (two) years and 8 (eight) months." [Annex Letter P]
Threatened with imprisonment for a maximum of 2 years 8 months (Article 231 of the Criminal Code). [Annex Letter P]
Certain places or rooms, movable and/or immovable property, data storage media, data access managed electronically, and other objects reasonably suspected of being used to store books/records/documents. [Article 14 paragraph 1]
Made in 2 (two) copies; the second copy is submitted to the Taxpayer, Representative, Proxy, employee, or adult family member. [Article 14 paragraph 4]
A list of places/rooms/items sealed, the owner's identity, and signatures of witnesses. [Annex Letter Q]
At least 2 adults other than the Audit team. [Article 14 paragraph 3]
The Tax Auditor makes a note about the refusal in the Sealing Minutes (the sealing remains valid). [Article 14 paragraph 5]
Prohibited from damaging, pulling off, removing the seal, or accessing, changing, deleting sealed books/records/documents (including electronic data). [Article 14 paragraph 11]
Damaging a seal is prohibited (criminal implications according to the Criminal Code/UU KUP). [Article 14 paragraph 11]
The Auditor must create minutes regarding the damage/loss of the seal mark and report it to the Indonesian National Police. [Article 14 paragraph 12]
The Taxpayer gives permission/assistance, sealing is no longer needed according to the Auditor, or there is a request from an investigator. [Article 14 paragraph 6]
Yes, unsealing must be witnessed by at least 2 (two) adults other than the Tax Audit team. [Article 14 paragraph 7]
The Tax Auditor makes a note about the refusal in the Unsealing Minutes. [Article 14 paragraph 9]
Based on the Tax Auditor's consideration that sealing is no longer needed, or there is a request from an investigator conducting an investigation into a tax crime. [Article 14 paragraph 6 letters b & c]
If after 7 days the seal may not be opened/the Taxpayer remains uncooperative. [Article 14 paragraph 13]
The Taxpayer must sign an Audit Refusal Statement at the latest 7 days after the Audit Notification Letter is delivered. [Article 15 paragraph 1]
A maximum of 7 days after the Audit Notification Letter is delivered. [Article 15 paragraph 1]
If after being sealed for 7 days the Taxpayer still does not give permission/assistance, the Taxpayer is deemed to have refused the audit and can be assessed ex-officio or proposed for Preliminary Evidence (Bukper). [Article 14 paragraph 13 jo. Article 15 paragraphs 2 & 4]
The Tax Auditor may perform a tax assessment ex-officio (calculating the tax due themselves) or propose a Preliminary Evidence Audit (criminal investigation) if there are indications of a tax crime. [Article 15 paragraph 4]
Audit refusal results in tax being calculated ex-officio, which can lead to the rejection of the refund application if data is insufficient to prove the truth of the application. [Article 12 paragraphs 14 & 15 - implications of ex-officio assessment]
The refusal can be a basis for consideration for the Director General of Taxes to make a decision in accordance with the audit purpose (e.g., rejecting an NPWP deletion or PKP revocation request). [Article 15 paragraph 5]
Yes, in accordance with Article 35 of the UU KUP. [Article 16 paragraph 4]
The information is recorded in the Audit Working Papers (not the Minutes). [Article 16 paragraph 5]
It is recorded in the minutes of providing third-party information. [Article 16 paragraph 6]
PTS is a discussion between the Taxpayer and the Tax Auditor regarding the preliminary audit findings, the results of which are recorded in minutes. The purpose is to provide assurance that the findings have been based on strong and relevant evidence and in accordance with laws and regulations. [Article 1 point 34; Article 5 paragraph 4 letter c]
Generally Yes, the Tax Auditor is obliged to perform PTS for an audit to test compliance. However, this obligation is excluded (not mandatory) if the audit is conducted using the Specific Audit type (e.g., Concrete Data audit). [Article 7 paragraph 2 letter e jo. paragraph 3]
The Taxpayer will receive a Summons Letter to Perform Discussion of Preliminary Findings accompanied by a List of Preliminary Findings. [Article 17 paragraph 2; Annex Letter V]
The list contains the Items for which information/discussion is requested, Value according to WP/SPT, Value according to the Auditor (preliminary findings), and other relevant information. [Annex Letter V, Numbers 20-22]
PTS must be performed at the latest 1 (one) month before the testing period ends. This provides sufficient time for the Taxpayer to refute before the SPHP is issued. [Article 17 paragraph 3]
For a Comprehensive Audit it is 5 months, and for a Focused Audit it is 3 months. Therefore, PTS for a Comprehensive Audit is performed at the latest in the 4th month, and for a Focused Audit in the 2nd month. [Article 6 paragraph 2; Article 17 paragraph 3]
The Taxpayer has the right to:
1. Provide additional books/records/documents/electronic data not yet submitted (including documents from third parties).
2. Show original evidence.
3. Bring witnesses, experts, or third parties to provide information/clarification. [Article 17 paragraph 4]
Yes, they can. The Taxpayer is given the opportunity to submit documents lent/requested that were with a third party and not previously obtained. [Article 17 paragraph 4 letter c]
The Taxpayer must deliver an appointment letter for the witness, expert, or third party to the Tax Auditor. [Article 17 paragraph 4 letter d]
Yes, recorded in the Minutes of Discussion of Preliminary Findings signed by the Tax Auditor and the Taxpayer (or Representative/Proxy). This document also records the list of new evidence submitted during the PTS. [Article 17 paragraph 5; Annex Letter Z]
The options are: Lent, Not yet lent, or Information/Expert Witness (dash mark). [Annex Letter Z, Filling Instructions Number 40]
The Tax Auditor will make a note regarding the non-attendance in the Minutes of Discussion of Preliminary Findings, and the audit will continue to the stage of preparing the SPHP based on the fiscal side's findings. [Article 17 paragraph 7]
Such action violates the Tax Auditor's Obligation (Article 7 paragraph 2 letter e) and violates the Audit Implementation Standards (Article 5). Although Article 21 of PMK 15/2025 only explicitly mentions the cancellation of an SKP due to the absence of SPHP or Final Discussion, failure to implement PTS is a procedural violation (maladministration) that can be reported, because it removes the Taxpayer's right to clarify findings early on. [Article 7 paragraph 2 letter e; Article 5; Article 29 (implicit regarding internal sanctions)]
Yes, they can. However, the Tax Auditor will make a note regarding the refusal to sign in the minutes. Refusal to sign does not invalidate the audit process. [Article 17 paragraph 6]
Such action is a violation of the Audit Implementation Standards and the Tax Auditor's Obligation.
Not necessarily. Based on the document format, the List of Preliminary Findings focuses more on the Items audited and the Value of the Taxable Base (DPP)/Business Turnover/Costs according to the Auditor compared to the Taxpayer's Tax Return.
Notification Letter of Audit Results accompanied by a list of findings. [Article 18 paragraph 1]
Contains the Tax Period/Year, Items corrected, Value according to the WP, Value according to the Auditor, Correction Amount, and Reason for Correction (Legal Basis). [Annex Letter AA Number 2]
A maximum of 5 (five) working days after the SPHP is received. [Article 18 paragraph 2]
Minutes are created stating that a response was not submitted. [Article 18 paragraph 3]
Not invalid. Article 27 paragraph (2) regulates the exception that the delivery of SPHP and the Written Response to SPHP can be performed directly or via facsimile (other than electronically). The Auditor can switch to the manual/direct delivery method to comply with the deadline without having to extend the audit timeframe. [Article 27 paragraph 2]
A maximum of 3 working days after the response is received or the response deadline ends. [Article 18 paragraph 6]
Discussion minutes, PAHP Minutes, and Summary of Final Discussion Results. [Article 18 paragraphs 7 & 8]
The Minutes and the Minutes of PAHP are signed unilaterally by the Auditor. [Article 18 paragraph 11]
In the case of an ex-officio assessment, the Tax Auditor must perform proof that the Taxpayer did not or under-submitted books, records, and/or documents, as well as other requested information. This means the Auditor must have valid administrative evidence (request letter, warning letter, minutes of request not being fulfilled) before calculating tax ex-officio. [Article 13; Article 12 paragraph 14]
In the case of an ex-officio assessment, the Tax Auditor must perform proof that the Taxpayer did not or under-submitted books, records, and/or documents, as well as other requested information. This means the Auditor must have valid administrative evidence (request letter, warning letter, minutes of request not being fulfilled) before calculating tax ex-officio. [Article 13; Article 12 paragraph 14]
Limited to the calculation of business turnover/gross and tax credit. [Article 18 paragraph 12]
Very limited, only:
They can be submitted until before the minutes of the Final Discussion of Audit Results (PAHP) are signed. [Article 12 paragraph 11]
Yes, documents other than those lent/requested can be submitted until before the minutes of PAHP are signed. [Article 12 paragraph 12]
Yes, the Tax Auditor will provide a note regarding the refusal to sign in the PAHP Minutes, but the Taxpayer's attendance is still recognized (not considered absent). [Article 18 paragraph 10]
The discussion minutes, PAHP Minutes, and Summary of Final Discussion Results will be signed unilaterally by the Tax Auditor, and tax will be calculated according to the Auditor's figures (if the WP refuses/partially agrees) or according to the SPHP (if the WP did not respond). [Article 18 paragraph 11; Article 20 paragraph 7]
If there is a difference of opinion on the legal basis of correction and the PAHP Minutes have not been signed. [Article 19 paragraph 1]
The application can be submitted if the Discussion Minutes have been signed, but the Minutes of Final Discussion of Audit Results (PAHP) have not been signed, and there are still differences of opinion limited to the legal basis of corrections. [Article 19 paragraph 1]
To the Head of the Regional Office of DGT (if the audit is performed by a KPP/Regional Office) or the Director of Audit and Collection (if the audit is performed by the P2 Directorate). [Article 19 paragraph 2]
The applicant's identity, SPHP number, and a comparison table of correction items (according to the SPHP, according to the Auditor, and according to the WP). [Annex Letter HH
Yes, a telephone/mobile number and facsimile of the WP's side must be included for communication with the QA Team. [Annex Letter HH, Numbers 16-18]
A maximum of 3 (three) working days calculated from the signing of the Discussion Minutes. [Article 19 paragraph 3]
The Tax Auditor will deliver a summons letter to the Taxpayer to sign the PAHP Minutes (QA right is deemed forfeited). [Article 19 paragraph 4]
Consists of 1 chairperson, 1 secretary, and 3 members. [Article 19 paragraph 6]
Yes, the QA Team Minutes contain conclusions and decisions of the discussion results which are binding and form the basis for creating the PAHP Minutes. [Article 19 paragraph 8 letter c & paragraph 16]
The discussion is still performed and the QA Team creates minutes of non-attendance. [Article 19 paragraphs 11 & 15]
Minutes of Taxpayer Non-attendance in Discussion with the QA Team. [Annex Letter LL]
As a basis for the Auditor to create the PAHP Minutes. [Article 19 paragraph 16]
Still uses the QA Team Minutes format (Annex KK), but the QA Team provides a note of refusal in the minutes. [Article 19 paragraph 14]
SKP (Underpayment/Nil/Overpayment) or STP. [Article 20 paragraph 3]
In accordance with the results of the Final Discussion. [Article 20 paragraph 7 letter a]
In accordance with the results of the Final Discussion. [Article 20 paragraph 7 letter a]
Tax is calculated according to the SPHP and the WP is deemed to agree. [Article 20 paragraph 7 letter e]
The tax due is calculated based on the SPHP and the Taxpayer is deemed to agree with the audit results. [Article 20 paragraph 8 letter e]
Tax is calculated based on:
The tax due is calculated based on the value according to the Tax Auditor at the time of the Final Discussion of Audit Results. [Article 20 paragraph 7 letter b]
The Tax Auditor creates a Calculation Note based on the Audit Result Report (LHP) as the basis for issuing the Tax Assessment Letter (SKP) or Tax Collection Letter (STP). [Article 20 paragraph 6 letter a]
Among others, if the WP is not found, the audit is terminated due to Preliminary Evidence, or the WP dies. [Article 20 paragraph 9]
Yes, a re-audit can be performed if the Taxpayer is found in the future. [Article 20 paragraph 13 letter a]
Yes, if the tax period/year has completely expired for assessment, except those related to Article 17 paragraph (1) or Article 17B of the UU KUP (restitution). [Article 20 paragraph 9 letter d]
The Re-audit is terminated by creating a Summary LHP and notifying the Taxpayer. [Article 25 paragraph 4]
An audit that has started for a tax period/year that has already completely expired for assessment must be terminated with a Summary LHP, except related to a restitution application (Article 17B) or Article 17 paragraph (1) of the UU KUP. [Article 20 paragraph 9 letter d]
No, it remains assessed ex-officio. [Article 20 paragraph 10]
If issued without the delivery of SPHP or without a Final Discussion. [Article 21 paragraph 1]
The audit is continued with the correct SPHP/Final Discussion procedures. [Article 21 paragraph 2
The 12-month period is suspended, calculated from the issuance date of the canceled SKP until the issuance of the Cancellation Decision. [Article 21 paragraph 3 letter a]
As long as the Auditor has not delivered the SPHP. [Article 22 paragraph 1]
A separate report, calculation of underpaid tax, and a Tax Payment Slip (SSP) for tax settlement + interest sanctions. [Article 22 paragraph 3]
A letter format to the Head of the KPP detailing the incorrect Tax Return elements (Tax Return value vs. actual vs. difference) and calculation of underpayment. [Annex Letter MM]
The tax settlement SSP is accounted for as a tax credit in the SKP, while the interest sanction SSP is treated as proof of sanction payment. [Article 22 paragraphs 6 & 7]
No, the audit is still continued to prove the truth of the disclosure. [Article 22 paragraph 5]
No, the SPOP is excluded from the disclosure of inaccuracies. [Article 22 paragraph 2]
Generally, both the Taxpayer and the Director General of Taxes can deliver audit documents through 3 (three) ways:
No. There is a special exception for the delivery of the Notification Letter of Audit Results (SPHP) by the Auditor and the Written Response to SPHP by the Taxpayer. For these two crucial documents, delivery is performed through:
Technical procedures for electronic document delivery follow the provisions of the Ministerial Regulation of Finance regulating tax provisions in the context of implementing the Core Tax Administration System (Coretax). [Article 27 paragraph (3)]
Following the Ministerial Regulation regarding procedures for implementing the core tax administration system (Coretax). [Article 27 paragraph 3]
If the audit is performed online, the signing of documents requiring the signatures of the Taxpayer and the Audit Team (such as Minutes) is performed electronically (electronic signature). [Article 27 paragraph (4)]
If both the Taxpayer and the Audit Team cannot perform an electronic signature (e.g., due to system down or technical constraints), the signing is performed manually using an ordinary signature (wet signature), the procedure for which is first performed by the Taxpayer, then by the Audit Team. [Article 27 paragraph 5]
The term used is "Ordinary Signature". [Article 27 paragraph 5]
The rule establishes a strict hierarchy: Signing is performed first by the Taxpayer, then signed by the Tax Audit Team. [Article 27 paragraph (5)]
According to the procedure, manual signing is performed first by the Taxpayer, then by the Tax Audit Team. The Taxpayer signs the document as a form of agreement/acceptance, which is then legalized by the Auditor's signature. [Article 27 paragraph 5]
Signing is performed first by the Taxpayer, then by the Tax Audit Team. This is to ensure the physical document held by the fiskus has been agreed to by the Taxpayer before being legalized by the auditor. [Article 27 paragraph 5]
Yes, still valid. Article 27 paragraph (5) explicitly regulates the procedure of signing using an ordinary signature as a valid fallback mechanism if the Taxpayer and the Tax Audit team cannot sign electronically. [Article 27 paragraph 5]
Yes, the document is valid and legally binding as audit administrative evidence. [Article 27 paragraph 5; General Explanation/State Administrative Law]
Conducted based on PMK 17/2013 as amended several times lastly by PMK 18/2021. [Article 30 letter a]
Conducted based on PMK 256/2014. [Article 30 letter b]
Uses the new administration format in accordance with PMK 15 of 2025. [Article 30 letter c]
On the date of promulgation (February 14, 2025). [Article 32]
Yes, revoked and declared no longer valid. [Article 31 letter a]
Yes, revoked and declared no longer valid. [Article 31 letter b]
Yes, revoked and declared no longer valid. [Article 31 letter c]
No, as long as the audit was performed in accordance with Audit Standards and in good faith. [Article 29]
The Minister of Finance of the Republic of Indonesia, Sri Mulyani Indrawati. [Closing/Signature]
February 10, 2025. [Closing/Signature]
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