The Directorate General of Taxes (DGT) is moving its tax compliance approach toward cooperative compliance. Beyond administrative changes, the approach encourages businesses to manage tax risks before they develop into disputes.
Ideatax Partner Cecilia Kartono said the shift reflects a move from reactive to preventive tax compliance. In her view, the foundation for this transformation was laid by the rollout of the Coretax system, which has given the DGT access to more comprehensive and structured taxpayer data.
“If audits were previously conducted after problems arose, companies are now encouraged to manage tax risks from the outset. That is the essence of cooperative compliance,” Cecilia said.
She elaborated that under this approach, fulfilling formal tax obligations, such as filing returns and paying taxes, is no longer sufficient on its own. Companies are also expected to establish sound tax governance that enables potential risks to be identified at an early stage.
Tax Control Framework
A central element of cooperative compliance is the tax control framework (TCF). Cecilia explained that the TCF is a tax governance framework promoted by the OECD to ensure that integrated controls, oversight, and risk management support a company’s tax processes.
In practice, companies need a clearly defined tax strategy that establishes parties responsible for identifying tax risks, sets approval procedures for transactions carrying tax implications, and provides a regular monitoring and evaluation mechanism for such risks.
“It is time for companies to build a TCF as the foundation of cooperative compliance,” she said.
Rising Number of SP2DKs
The DGT’s expanding use of taxpayer data is also reflected in the growing number of requests for explanation of data and/or information (surat permintaan penjelasan atas data dan/atau keterangan/SP2DK) issued to taxpayers. According to Cecilia, the uptick is closely linked to the DGT’s increasing ability to access and analyze taxpayer data as part of the cooperative compliance ecosystem.
“Throughout the first half of 2026, the DGT issued approximately 250,000 SP2DKs, up about 35% from approximately 185,000 during the same period last year. This trend has emerged as it has become easier for the DGT to access taxpayer data,” she said.
Looking ahead to the second half of 2026, Cecilia expects the number of SP2DKs to potentially continue rising as the tax authority makes greater use of available data. She therefore urges companies to review their tax positions without waiting for an SP2DK to arrive.
“A tax strategy is essential for identifying tax risks from the outset. That strategy should be put in place before the company receives an SP2DK,” she said.
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