Effective October 1, 2026, the Directorate General of Taxes (DGT) has implemented Director General of Taxes Regulation No. PER-12/PJ/2026. The regulation replaces PER-11/PJ/2025 and changes the mechanism for filing amended tax returns (surat pemberitahuan/SPT) in Coretax from the delta scheme to the replace scheme.
Under the delta scheme, an amended tax return records only the difference from the previously filed return. This mechanism can result in pseudo-underpayment, a situation in which the system indicates a tax shortfall even though the taxpayer’s overall tax position shows an overpayment.
Under the replace scheme, an amended tax return fully replaces the previous return as the basis for calculating tax for the relevant tax period. Therefore, the amended return must contain complete and accurate transaction data and tax calculations, rather than merely recording changes to the previous return.
Coretax will recalculate the tax liability based on all the data in the amended return. The system will also take into account payments already made for the relevant tax period, including payments associated with the original return and any previous amended returns, as well as overpayments that have already been refunded or credited against future tax liabilities.
This change introduces three risks that taxpayers need to consider, particularly when responding to findings outlined in requests for explanation of data and/or information (surat permintaan penjelasan atas data dan/atau keterangan/SP2DK).
1. Risk of System Validation Rejection
The replace scheme requires taxpayers to prepare amended returns containing complete data. However, SP2DKs often present findings as aggregate figures without providing details of the underlying transactions.
If taxpayers directly enter these aggregate figures into an amended return without breaking them down into the underlying transactions, or use invalid third-party identification details, Coretax may reject the filing.
To mitigate this risk, taxpayers need to reconcile their transaction data and ensure that all reported information is complete, accurate, and compliant with applicable regulations.
2. Risks to Tax Refund Applications
Taxpayers applying for refunds of tax overpayments need to pay attention to the specific provisions under PER-12/PJ/2026 governing amendments to tax returns while refund applications are being processed.
If an amended return affects a refund application that is already being processed, taxpayers should assess the implications for the ongoing process before filing the amendment. This step is necessary to ensure that the amendment complies with applicable regulations and does not result in adverse consequences.
3. Risks of Changes to Tax Credit Carryforwards and Cash Flow
Under the replace scheme, changes to tax return data can affect a taxpayer’s tax position and credit carryforward balance for the relevant tax period. An amendment can also change an overpayment balance that has already been carried forward to subsequent tax periods.
If an overpayment balance from a previous period decreases following an amendment, taxpayers need to recalculate their tax positions for all affected periods. Such changes may result in underpayments in subsequent tax periods and require taxpayers to amend their returns sequentially.
Before filing an amendment, taxpayers should reconcile their credit carryforward balances and assess the implications for their tax liabilities and corporate cash flow.
Also Read:
Tax Bulletin: SP2DK Challenges in Amending Tax Returns in the Coretax Era
SP2DK Findings Without Transaction Details: What Taxpayers Need to Know
Understanding SP2DK: Purpose, Process, and How to Respond
Writer: Arianta John Bangun | Editor: Thomas Rizal
