5 Things to Know About Indonesia’s
Global Minimum Tax

The Directorate General of Taxes (DGT) has taken another step toward implementing the global minimum tax by issuing the Director General of Taxes Regulation Number PER-6/PJ/2026 concerning Procedures for Exercising Rights and Fulfilling Obligations under the Global Minimum Tax Based on International Agreements. The regulation covers a wide range of administrative requirements, including taxpayer registration, filing obligations, reporting procedures, and top-up tax payments.

As Indonesia aligns itself with the international consensus, there are at least five essentials businesses should know.

1. PER-6/PJ/2026 Puts the Global Minimum Tax Into Practice

    

   The global minimum tax framework did not begin with PER-6/PJ/2026. Rather, the regulation serves as the technical rulebook for implementing provisions previously introduced by the Minister of Finance Regulation Number 136 of 2024 concerning the Implementation of the Global Minimum Tax Based on International Agreements and Government Regulation Number 55 of 2022 concerning Adjustments to Income Tax Provisions.

   While those regulations established the legal foundation for the global minimum tax, PER-6/PJ/2026 provides the operational details necessary to make the system work in practice. It further regulates the provisions of Article 54, Paragraph 2, of Government Regulation Number 55 of 2022, and Article 65, Paragraph 15, of Minister of Finance Regulation Number 136 of 2024.

    

2. Not Every Company Falls Within Scope

    

   The regulation applies only to constituent entities within a multinational group, including certain permanent establishments and joint venture entities, that have annual consolidated revenue exceeding EUR 750 million and are subject to the GloBE rules.

   A constituent entity is generally an entity that is part of an MNE group, including a permanent establishment of the ultimate parent entity within the group.

   Companies that meet the threshold will be required to file an income tax return under Indonesia’s global minimum tax regime.

    

3. Eligible Taxpayers Must Register for GloBE Status

    

   One of the main administrative requirements introduced by PER-6/PJ/2026 is the obligation to obtain GloBE taxpayer status. Taxpayers who meet the criteria must submit an application electronically no later than 9 months after they are first classified as a GloBE taxpayer.

   

    

4. The Global Minimum Tax Reporting Requirements

    

   Compliance under the global minimum tax goes well beyond filing a standard tax return. The regulation introduces several types of filings, including:

   1. GloBE income tax returns;
   2. Undertaxed Payments Rule (UTPR) returns; and
   3. Domestic Minimum Top-Up Tax (DMTT) returns.

    

   Supporting schedules must also accompany the filings, covering appendices such as:

   Appendix I (Heading 3)

   1. Part A: Top-up tax under the Income Inclusion Rule (IIR)

   2. Part B: Top-up tax under DMTT in Indonesia

       

   Appendix II (Heading 3)

   1. Top-up tax under UTPR allocated to GloBE taxpayers

       

   Appendix III (Heading 3)

   1. Part A: GloBE profit or loss
   2. Part B: Adjusted covered taxes
   3. Part C: International shipping income exclusions
   4. Part D: Substance-Based Income Exclusion (SBIE) calculations
   5. Part E: Additional current top-up tax adjustments
   6. Part F: Top-up tax under DMTT for GloBE taxpayers

    

   

    

5. Tax Return Filing Deadlines

   Global minimum tax returns must generally be submitted within 4 months after the end of the relevant GloBE fiscal year. Taxpayers may request an extension, although it must be submitted within the timeframe specified by the regulation.

    

   In addition to filing tax returns, affected entities must also notify the tax authority regarding the group’s reporting structure, including:

   1. the identity of the ultimate parent entity;
   2. details of resident constituent entities; and

   3. the party designated to file the GloBE Information Return (GIR).

       

   These are the five crucial things taxpayers should understand about the procedures for exercising rights and fulfilling obligations under Indonesia’s global minimum tax regime. As the new rules take effect, affected taxpayers should familiarize themselves with the administrative requirements to ensure compliance with the applicable regulations.

    

   For further guidance on the global minimum tax, Ideatax is ready to assist.

Also read:

Article 26 Withholding Tax on Foreign Taxpayers

Navigating Tax Payments in the New Coretax System

The Chart of Accounts for Coretax Reporting