Transformation of Concrete Data Execution: Mechanism and Procedures of Specific Audit in the Coretax Era (PMK 15 & PER-18 of 2025)

In the dynamic landscape of Indonesian taxation, the year 2025 marks a fundamental shift in the law enforcement strategy by the Directorate General of Taxes (DGT). With the enactment of Minister of Finance Regulation Number 15 of 2025 (PMK 15/2025) regarding Tax Audit and its implementing regulation, Director General of Taxes Regulation Number PER-18/PJ/2025, the DGT introduces a more aggressive, rapid, and measured approach in handling what is termed as "Concrete Data" (Data Konkret).

This article will narratively outline the mechanism and procedures for handling Concrete Data, from identification and classification to execution through Specific Audit, and compare it with past practices to provide a complete picture for Taxpayers.

1. Philosophy of Concrete Data: From Indication to Absolute Proof

Before understanding the mechanism, we need to understand what Concrete Data is through the lens of the latest regulations. Unlike risk analysis data (such as financial ratio analysis) which is still an indication, Concrete Data is data that possesses an absolute degree of certainty.

The keyword "directly used" drastically changes the audit procedure. Tax authorities no longer need to perform complicated cash flow or goods flow testing; they simply need to match system data with the Taxpayer's Tax Return (SPT) reporting. If it doesn't match, it is a finding.

2. Scope and Classification of Data (PER-18/PJ/2025)

In Article 2 of PER-18/PJ/2025, the scope of Concrete Data is clarified into four main categories that form the basis of the audit:

1. Output Tax Invoices: Tax Invoice data that has received approval from the DGT system but has not been reported in the VAT Period Return. This is the result of e-Faktur validation.
2. Income Tax Withholding Slips: Withholding/collection slips that have been issued (via e-Bupot) but not reported in the Income Tax Period Return.
3. Non-Filer Data: Economic transaction data belonging to Taxpayers who do not submit Tax Returns (Period/Annual) within the specified time, and remain non-compliant after being warned in writing.
4. Other Transaction Proofs: This includes data that has been clarified through a Request for Explanation on Data and/or Information (SP2DK), where the Taxpayer admits to the data in the Minutes (Berita Acara) but does not correct the Tax Return or pay the tax.

3. Handling Mechanism: The Fast Track

Under the old regime (SE-15/2018), concrete data was often handled through the Special Audit mechanism which followed procedures similar to routine audits, taking months. However, PMK 15/2025 introduces the "Specific Audit" (Pemeriksaan Spesifik) type designed specifically for this data.

A. Preparation and Assignment Phase

The mechanism begins when the DGT system (Coretax) or Account Representative (AR) detects Concrete Data. Based on PER-18/PJ/2025, this data no longer needs to go through deep risk analysis. The Head of the Tax Service Office (KPP) can directly instruct the issuance of a Tax Audit Warrant (SP2) with the Specific Audit type.

B. Audit Execution Phase (Speed Audit)

This is the most radical change. The audit timeline is slashed extremely to ensure rapid legal certainty:

• Testing Period: Examiners only have a maximum of 10 (ten) working days to perform testing.
• Reporting Period: The drafting of the Audit Report (LHP) must be completed within 10 (ten) working days after the SPHP.

The total maximum duration is only about 20 working days. Compare this to a Comprehensive audit which can take over 5 months. Taxpayers are demanded to respond with high speed.

C. Elimination of Preliminary Findings Discussion

In standard audit mechanisms, there is a Preliminary Findings Discussion stage before the SPHP is issued. However, for Specific Audits of Concrete Data, this stage is eliminated [PMK 15/2025]. The logic is sound: since the data is already concrete, there is nothing to debate in terms of initial substance.

4. Settlement Procedures and Legal Products

After the SP2 is issued and delivered to the Taxpayer, the process proceeds as follows:

1. Simple Testing: The Examiner validates the data. For example, checking if Tax Invoice Number 010.000-24.0000001 is truly missing from the Taxpayer's VAT Period Return.
2. Issuance of SPHP: Within less than 10 working days, the SPHP is issued. This SPHP contains the tax correction plus administrative sanctions.
3. Taxpayer Response: Taxpayers are given a very short time to respond. Rebuttals are usually only accepted if they can prove incorrect input or reporting in a different period.
4. Closing Conference: This is the Taxpayer's final chance. If the Taxpayer agrees or provides no response, the Examiner immediately issues the LHP and legal products (SKPKB/SKPKBT).

5. Relationship with SP2DK (Supervision)

PER-18/PJ/2025 provides a bridge between the supervision function (AR) and the audit:

Conclusion

The mechanism for handling Concrete Data in PMK 15/2025 and PER-18/PJ/2025 reflects the DGT's paradigm shift from manual-based to system-based enforcement. By eliminating unnecessary stages and limiting the time to only 20 working days, the state aims to ensure that non-compliance can be acted upon immediately. For Taxpayers, this is a warning to strengthen internal data reconciliation, as the room for delay has now been firmly closed.

Reference:

1. Law Number 6 of 1983 as amended lastly by Law Number 6 of 2023 (UU KUP).
2. Government Regulation Number 50 of 2022.
3. Minister of Finance Regulation Number 15 of 2025 (Tax Audit).
4. Director General of Taxes Regulation Number PER-18/PJ/2025 (Follow-up on Concrete Data).
5. Director General of Taxes Regulation Number PER-23/PJ/2013.
6. Director General of Taxes Circular Letter Number SE-09/PJ/2023.
7. Director General of Taxes Circular Letter Number SE-15/PJ/2018.