The Last Bastion of Justice: Dynamics and Procedures of the Final Discussion of Audit Results (Closing Conference) in the Coretax Era

In the tax audit cycle, there is one crucial phase that serves as the culmination of the entire compliance testing series: the Final Discussion of Audit Results (Pembahasan Akhir Hasil Pemeriksaan - PAHP), often referred to as the Closing Conference. This phase is not merely an administrative formality, but the most vital moment for Taxpayers to defend their arguments, present rebuttals, and reach an agreement—or disagreement—in a dignified manner with the tax authorities before the Tax Assessment Letter (SKP) is issued.

Entering 2025, the tax audit landscape in Indonesia undergoes significant transformation with the enactment of Minister of Finance Regulation Number 15 of 2025 (PMK 15/2025). This regulation, aligned with the implementation of the Coretax System, brings fundamental changes regarding timelines, procedural rights, and dispute resolution mechanisms at the final audit stage. This article will thoroughly dissect the anatomy of PAHP, from the issuance of the Notification Letter of Audit Results (SPHP) to the signing of the official report, as well as strategies that Taxpayers must understand.

1. The Gateway: Notification Letter of Audit Results (SPHP)

The PAHP process does not begin when the face-to-face meeting occurs, but when the Notification Letter of Audit Results (SPHP) is issued. The SPHP is a legal document containing the examiner's preliminary findings, including corrected items, correction values, legal basis for corrections, as well as preliminary calculations of tax payable and sanctions [PMK 15 Year 2025, Article 1 number 35].

In the PMK 15/2025 regime, there are stricter procedures that must be observed:

• Delivery of SPHP: The Tax Examiner is obliged to deliver the SPHP along with the List of Audit Findings to the Taxpayer [PMK 15 Year 2025, Article 18 paragraph 1].
• Obligation to Respond (Strict Timeline): Taxpayers are obliged to provide a written response to the SPHP. A radical change occurs here: the response time is now cut to a maximum of 5 (five) working days from the receipt of the SPHP, and cannot be extended [PMK 15 Year 2025, Article 18 paragraph 2; IAI RTD Video Transcript]. Compare this with the old rule which gave 7 days plus a 3-day extension. This demands very high audit readiness from the Taxpayer.
• Consequence of No Response: If the Taxpayer does not submit a response within 5 working days, the Taxpayer is deemed to agree to the entire audit result, and the PAHP is deemed to have been conducted [PMK 15 Year 2025, Attachment AA Filling Instructions; SE-28/PJ/2017].

2. Invitation and Execution of Final Discussion

After the SPHP response phase, the Tax Examiner will send an Invitation for Final Discussion of Audit Results. This is an official summons for a face-to-face meeting (or via electronic media) to discuss disputed findings.

A. Discussion Timeframe

The PAHP process, from the delivery of the SPHP to the signing of the PAHP Official Report, must be completed within a strict timeframe:

• For Comprehensive, Focused, and Specific Audits: Maximum 30 (thirty) working days.
• For Concrete Data Audits: Maximum 10 (ten) working days [PMK 15 Year 2025, Article 6 paragraph 3].

B. Discussion Agenda

In this forum, the Taxpayer and Tax Examiner will dissect each correction item.

• Minutes of Discussion (Risalah Pembahasan): Every argument, rebuttal, and evidence discussed will be recorded in a document called the Minutes of Discussion. This document is vital as it becomes the track record of argumentation used if the dispute continues to the objection or appeal stage [PMK 15 Year 2025, Article 18 paragraph 7].
• Role of Follow-up Documents: Based on Article 12 paragraphs (11) and (12) of PMK 15/2025, documents previously borrowed but not yet provided, or documents other than those requested, can still be submitted and considered by the examiner up until before the PAHP Official Report is signed. This is the "last chance" for the Taxpayer to complete the evidence.

3. Limitation of Rights in Ex-Officio Audits

4. Quality Assurance (QA) Mechanism: Internal Referee

One of the Taxpayer rights protection features strengthened in PMK 15/2025 is the request for discussion with the Audit Quality Assurance (QA) Team.

• Submission Requirements: Disputes limited to the legal basis of correction [Article 19 paragraph 1].
• Timing: Request within 3 working days since Minutes of Discussion are signed, but before PAHP Official Report is signed.
• Exception: QA cannot be requested for Specific Audits (concrete data).
• Output: The QA Team's decision is final and binding for the Audit Team.

5. Finalization: Official Report and Summary of Results

The end of this process is the signing of two key documents:

1. Official Report of Final Discussion of Audit Results (Berita Acara PAHP).
2. Summary of Final Discussion Results (Ikhtisar Hasil Pembahasan Akhir).

Signing Scenarios:

• If Agreed: Both parties sign.
• If Refusing: Examiner makes a note of refusal; process continues to LHP and SKP.
• If Absent: Official Report is signed unilaterally by the Examiner.

Summary of Procedures and Rights-Obligations in PAHP

Conclusion

The Process of Final Discussion of Audit Results in the PMK 15 of 2025 era demands high responsiveness from Taxpayers. The disappearance of the SPHP response time extension option and the strict rules regarding ex-officio documents are signals that "delays" are no longer tolerated. For Taxpayers, PAHP is the last line of defense; utilizing it with thorough preparation is the key to obtaining a fair tax assessment.

Reference:

1. SDSN UU KUP 2023.
2. PP Number 50 of 2022.
3. PMK Number 15 of 2025.
4. PMK Number 118 of 2024.
5. SE-15/PJ/2018; SE-28/PJ/2017.
6. Slides of PMK-15 of 2025 Tax Examination.
7. PER-23/PJ/2013 Audit Standards.