Pillars of Integrity and Professionalism: Tax Audit Standards in the New Tax Landscape (PMK 15/2025)

In Indonesia's dynamic tax system, tax audit serves as the primary check and balance mechanism to ensure that the self-assessment system operates fairly and accountably. The definition of an audit according to the law is very clear: a series of activities to collect and process data, information, and/or evidence carried out objectively and professionally based on an audit standard [SDSN UU KUP 2023, Article 1 number 25].

The phrase "based on an audit standard" is the key that distinguishes a legitimate audit action from an arbitrary one. These standards act as a quality barometer binding the Tax Examiners. Entering a new era of tax administration with the issuance of Minister of Finance Regulation Number 15 of 2025 (PMK 15/2025), the provisions regarding Audit Standards are explicitly reaffirmed in Article 5, simplifying yet strengthening the essence of previous regulations (such as PER-23/PJ/2013).

This article will deeply dissect the standards that must be adhered to by the tax authorities in carrying out their duties, divided into three main pillars: General Standards, Implementation Standards, and Reporting Standards.

1. General Standards: Examiner Personal Qualifications

General Standards are personal standards related to the requirements of a Tax Examiner. An audit cannot be conducted by just anyone; it must be performed by functional officials or officers who meet strict qualifications. Based on Article 5 paragraph (3) of PMK 15 of 2025, the General Standards for Tax Examiners include the following minimum requirements:

• Technical Competence:  Auditors must receive adequate technical education and/or training and possess the necessary skills of a Tax Auditor [MoF Regulation No. 15 of 2025, Article 5 paragraph (3)a]. This ensures that auditors possess a comprehensive understanding of tax law, accounting, and auditing techniques prior to conducting fieldwork. Under technical guidelines (DGT Regulation No. PER-23/PJ/2013), it is further elaborated that audits may be conducted by external experts from outside the DGT who are appointed by the DGT [DGT Regulation No. PER-23/PJ/2013, Article 3 paragraph (3)].
• Integrity and Independence: Examiners must possess integrity and independence in carrying out their duties [PMK 15 Year 2025, Article 5 paragraph 3b]. This means examiners must be honest, free from disgraceful acts, and unaffected by pressure from any party, including the Taxpayer. Independence is crucial to maintaining the objectivity of audit results.

2. Implementation Standards: Process Governance

Implementation Standards govern how the audit process itself must be executed, from preparation to testing. PMK 15 of 2025 provides concise yet dense guidelines regarding these standards in Article 5 paragraph (4). Here are the details of the Audit Implementation Standards:

• Thorough Preparation: Examiners are required to conduct preparation in accordance with the audit objectives [PMK 15 Year 2025, Article 5 paragraph 4a]. This preparation covers data collection, risk analysis, and the drafting of an Audit Plan and Audit Program [PER-23/PJ/2013, Article 4 letter a].
• Method and Technique-Based Testing: Audits must be conducted by performing testing based on audit methods and techniques [PMK 15 Year 2025, Article 5 paragraph 4b]. Methods can be direct (document testing) or indirect (net worth/cost of living approaches) [SE-65/PJ/2013].
• Evidence-Based: Audit findings must be based on strong and relevant evidence and grounded in tax laws and regulations [PMK 15 Year 2025, Article 5 paragraph 4c]. This prevents assumptive corrections.
• Flexible Audit Locations: Audits are conducted at the DGT office, Taxpayer's residence, business location, or other necessary places [PMK 15 Year 2025, Article 5 paragraph 4d].
• Audit Working Papers (KKP) Documentation: Every step and conclusion must be documented in the form of Audit Working Papers (KKP) [PMK 15 Year 2025, Article 5 paragraph 4e]. KKP is the "heart" of audit accountability.

3. Reporting Standards: Accountable Output

The final stage of an audit is reporting. Reporting Standards ensure that the examiner's work is communicated clearly and formally. Based on Article 5 paragraph (5) of PMK 15 of 2025:

• Based on KKP: The Audit Result Report (LHP) must be compiled based on the Audit Working Papers (KKP) [PMK 15 Year 2025, Article 5 paragraph 5a].
• LHP Content: The LHP contains details on the audit execution, conclusions, and proposals, compiled concisely and clearly [PMK 15 Year 2025, Article 5 paragraph 5b].
• Summary LHP (LHP Sumir): Used when an audit is terminated because the Taxpayer cannot be found or does not fulfill summons [PMK 15 Year 2025, Article 20 paragraph 2].
• Basis for Tax Assessment: The LHP serves as the absolute basis for issuing Tax Assessment Letters (SKP) or Collection Letters (STP) [PMK 15 Year 2025, Article 20 paragraph 3].

Protection for Good Faith Examiners

The regulation provides legal protection for Tax Examiners. Article 29 of PMK 15 of 2025 asserts that Tax Examiners are not subject to sanctions if the Audit conducted is in accordance with Audit Standards and carried out based on good faith [PMK 15 Year 2025, Article 29].

Conversely, for Taxpayers, understanding these standards is a control tool. If an audit deviates from these standards, the Taxpayer has strong grounds to file an objection or complaint.