The Directorate General of Taxes (DGT) of the Ministry of Finance will strengthen oversight of multinational companies' tax obligations through the automatic exchange of information with the tax authorities of other countries. This mechanism is scheduled to take effect in 2027 after Indonesia joined the international agreement on the exchange of Global Anti-Base Erosion (GloBE) information.
According to an official statement from the DGT, Indonesia has signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA). The signing was carried out by the Director General of Taxes, Bimo Wijayanto, during the 13th Competent Authorities Conference held in Kotor, Montenegro, from October 27 to 29, 2026.
Referring to the Organisation for Economic Co-operation and Development (OECD) list as of October 1, 2026, Indonesia is recorded as the 41st country to have signed the agreement.
The GIR MCAA is a cooperation instrument that allows tax authorities to obtain information regarding the application of GloBE provisions by multinational enterprise groups conducting business activities across multiple jurisdictions.
This information is compiled through the GloBE Information Return (GIR), a standardized report containing data on multinational enterprise groups and information related to their compliance with the Global Minimum Tax (GMT) provisions.
With this agreement, the DGT will eventually be able to receive GIR reports from the jurisdictions where multinational enterprise groups operate. This data can be used to support the oversight of the calculation and fulfillment of GMT obligations.
The GMT provision applies to multinational enterprise groups with annual consolidated revenues of at least EUR 750 million. This policy aims to ensure that these enterprise groups are subject to a minimum effective tax rate of 15% in every jurisdiction where they operate.
The Automatic Exchange of Information (AEOI) through the GIR MCAA is planned to commence in 2027. However, its implementation will not automatically apply to all signatory countries, as each exchange relationship must first meet the requirements and be activated by the respective competent authorities.
This mechanism allows the DGT to obtain tax information from partner countries without relying entirely on separate reporting submitted in each country.
This cooperation also provides administrative convenience for multinational companies. Through a central filing mechanism, enterprise groups can submit their GIR through a single qualifying jurisdiction, reducing the obligation to submit duplicate reports to the various countries where they operate.
To activate the information exchange relationship, each tax authority must submit a notification to the Coordinating Body Secretariat. Furthermore, both jurisdictions must list each other as parties that both send and receive information.
The confidentiality aspect is also a crucial part of implementing this agreement. All exchanged data must be protected and can only be utilized in accordance with the provisions of the Convention on Mutual Administrative Assistance in Tax Matters (MAAC).
The signing of the GIR MCAA also reinforces Indonesia's steps in expanding international tax transparency. The agreement was drafted based on Article 6 of the MAAC, which has been ratified by Indonesia, and serves as one of the supporting instruments for implementing the GloBE rules as stipulated in the Minister of Finance Regulation Number 136 of 2024.
In addition to expanding access to tax information, Indonesia is also pushing for stronger international cooperation on cross-border assistance in recovering tax claims.
At the same conference, the Director General of Taxes also served as a keynote speaker in a special session on developing cross-border tax claim recovery assistance initiatives.
This push is motivated by the increasing mobility of capital and assets across jurisdictions. This condition can make it difficult for tax authorities to collect tax obligations when the assets or the parties responsible for tax payments are located outside their jurisdictions.
Indonesia has also invited partner countries that still limit the implementation of the tax claim recovery assistance provisions in the MAAC to consider withdrawing their reservations. Another alternative is to expand cooperation through bilateral agreements.
Furthermore, Indonesia is encouraging the use of the Model Manual developed by the Global Forum as a technical guideline for countries in establishing mechanisms for cross-border tax claim recovery assistance.
Indonesia's commitment in this area is reflected in, among others, Presidential Regulation Number 56 of 2024, which limits reservations on tax claim recovery assistance to certain types of taxes. Another foundation is found in Law Number 7 of 2021 concerning Harmonization of Tax Regulations, which also regulates the mechanism for tax claim recovery assistance.
The 13th Competent Authorities Conference was organized by the Global Forum on Transparency and Exchange of Information for Tax Purposes in collaboration with the Montenegrin tax authority. The three-day forum was attended by representatives from 90 jurisdictions, including the United Kingdom, the United States, France, Japan, and South Korea.
One of the issues highlighted in the conference was the effectiveness of utilizing tax information. The success of cross-border data exchange is considered to be determined not solely by the amount of information successfully gathered, but also by the tax authorities' ability to process and utilize it to produce a tangible impact on tax administration.
For Indonesia, access to GIR reports is expected to strengthen oversight of the GMT implementation while enhancing the DGT's ability to identify potential non-compliance. This step is also part of an effort to narrow the room for tax avoidance and evasion practices that exploit jurisdictional differences.
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Writer: Fiorentina Renata Trixie | Editor: Thomas Rizal
