The Culmination of Tax Audit: Dissecting the Audit Report (LHP) and Summary Audit Report (LHP Sumir) in the Modern Tax Regime

In the Indonesian tax ecosystem, every compliance testing action conducted by the Directorate General of Taxes (DGT) must lead to legal certainty. The culmination of the long series of audit procedures—starting from the delivery of the Audit Warrant (SP2), document borrowing, cash flow testing, to the final discussion—is a vital document called the Tax Audit Report (Laporan Hasil Pemeriksaan - LHP).

For Taxpayers, the LHP is not merely an internal administrative document of the tax authority. The LHP is the "crown" of the audit process which serves as the legal basis for issuing a Tax Assessment Letter (SKP). Entering the Coretax System era with the enactment of Minister of Finance Regulation Number 15 of 2025 (PMK 15/2025), understanding the anatomy of the LHP, including its variant called LHP Sumir (Summary Audit Report), becomes crucial. This article will thoroughly explore everything related to the LHP, from definitions and functions to drafting and legal implications.

1. Basic Concept and Legal Standing of LHP

Based on Article 1 number 38 of PMK 15 of 2025, the Tax Audit Report (LHP) is defined as a report containing the execution and results of an Audit prepared by the Tax Examiner in a concise and clear manner and in accordance with the scope and objectives of the Audit [PMK 15 Year 2025, Article 1 number 38].

Vital Functions of LHP:

The LHP has strategic dual functions:

1. Basis for Issuance of Assessment: The LHP is the absolute basis for the DGT to issue Tax Assessment Letters (SKPKB, SKPN, SKPLB), Land and Building Tax Assessment Letters, and/or Tax Collection Letters (STP) [PMK 15 Year 2025, Article 20 paragraph 3]. Without an LHP, an SKP has no legal standing.
2. Examiner's Accountability: The LHP is the manifestation of the Tax Examiner's accountability, proving that the audit was conducted according to standards [PER-23/PJ/2013, Article 5].

2. The Foundation of LHP: Audit Working Papers (KKP)

An LHP must not be compiled based on mere assumptions. Article 20 paragraph (4) of PMK 15 of 2025 asserts that the LHP must be compiled based on Audit Working Papers (Kertas Kerja Pemeriksaan - KKP).

KKP are detailed records regarding the procedures taken, evidence collected, tests performed, and conclusions drawn [PER-23/PJ/2013, Article 1 number 12]. KKP must be compiled completely, accurately, objectively, and systematically so they can serve as a reference in case of disputes (Objection/Appeal) [SE-08/PJ/2012].

3. Anatomy and Content of the Tax Audit Report

Referring to the Audit Reporting Standards and SE-28/PJ/2017, a standard LHP (for compliance testing) must be compiled concisely and clearly with a standardized structure, including:

A. General Section

Contains Taxpayer identity, audit assignment (SP2 number), and tax compliance fulfillment (payment and reporting profile). This section also covers business activity overview and special relationships (affiliations) if any [SE-28/PJ/2017, Section E].

B. Audit Execution

Records the chronology of the audit, starting from:

• Delivery of the Notification of Tax Examination.
• Document borrowing (including constraints if documents are not provided).
• Delivery of SPHP (Notification of Audit Results).
• Execution of the Final Discussion (Closing Conference). The Minutes of Discussion and the Official Report of Final Discussion (BA PAHP) documents are inseparable parts of the LHP [PMK 15 Year 2025, Article 20 paragraph 5].

C. Audit Results (Core of LHP)

This is the most important part containing:

1. Description of Audit Results: In-depth explanation regarding corrected items, legal basis for corrections, and mathematical calculations [SE-28/PJ/2017].
2. Summary of Audit Results: Summary of figures according to the Tax Return vs. according to the Examiner, and the amount of administrative sanctions.
3. Conclusion and Proposal: Recommendation for issuance of SKP (Underpayment/Nil/Overpayment).

D. Executive Summary

To facilitate decision-making by the Head of Unit (Head of KPP/Regional Office), the LHP must be equipped with an Executive Summary containing a summary of the 5 (five) largest corrections [SE-28/PJ/2017, Letter A Number 5].

4. LHP Sumir: Termination of Audit Without SKP

Not all audits end with the issuance of an SKP containing tax payable. In certain conditions, the audit is terminated by creating a Summary Audit Result Report (LHP Sumir).

Definition of LHP Sumir: It is a report containing the termination of an Audit without a proposal for the issuance of a tax assessment letter [PMK 15 Year 2025, Article 1 number 39].

When is LHP Sumir Created? Based on Article 20 paragraph (9) of PMK 15 of 2025, LHP Sumir is created in the following conditions:

1. Taxpayer Not Found: If within the testing period the Taxpayer or their representative cannot be found.
2. Audit Suspended (Criminal Realm): If the audit is upgraded to a Preliminary Evidence Examination (Bukper) and subsequently resolved through Article 8 paragraph 3 KUP Law, Article 44B KUP Law, or has reached inkracht [PMK 15 Year 2025, Article 23 paragraph 7].
3. Re-Audit Resulting in No Underpayment: If new data turns out not to cause additional tax.
4. Consideration of Director General of Taxes: For other special conditions, e.g., audit on net asset data post-Tax Amnesty which is not proven.

5. Digital Implications: LHP in the Coretax Era

PMK 15 of 2025 brings the spirit of digitalization. LHP compilation is now integrated with the DGT information system (Coretax). Supporting documents are managed electronically.

• Document Delivery: Taxpayers can receive audit result documents through the Taxpayer's account on the DGT portal [Article 27].
• Data Security: Electronic data forming the basis of the LHP must go through imaging and hashing processes [SE-36/PJ/2017].

6. Taxpayer Strategy Facing LHP

LHP is the first-degree "verdict." Taxpayers must be critical:

1. Check Consistency: Ensure the figures in the LHP match exactly with the figures agreed upon in the Official Report of Final Discussion.
2. Study Legal Basis: The examiner is obliged to state the legal basis. If based only on assumptions, this is a strong loophole for filing an Objection.
3. Understand LHP Sumir: If received due to Preliminary Evidence, realize your status shifts from administrative to criminal risk. Immediately consult on mitigation steps.

Conclusion

The Tax Audit Report (LHP) is the culminating document that transforms raw data and arguments into binding tax assessments. Both standard LHP and LHP Sumir have serious legal consequences strictly regulated in PMK 15 of 2025. Understanding their structure and issuance triggers gives Taxpayers an advantage in mitigating future tax dispute risks.

Reference:

1. SDSN UU KUP 2023 (Law on General Provisions and Tax Procedures).
2. PP Number 50 of 2022 concerning Procedures for the Exercise of Rights and Fulfillment of Tax Obligations.
3. PMK Number 15 of 2025 concerning Tax Examination.
4. PER-23/PJ/2013 concerning Audit Standards.
5. SE-28/PJ/2017 concerning Guidelines for Preparation of Audit Result Reports.
6. SE-15/PJ/2018; SE-08/PJ/2012; SE-65/PJ/2013; SE-36/PJ/2017.
7. Transcript of Video "RTD - Thorough Discussion of Tax Audit in the Coretax Era Based on PMK No. 15 of 2025".