May 2025 has emerged as a pivotal month for the Directorate General of Taxes (DGT), which issued no fewer than six new regulations in the year’s first half. Among them is the Director General of Taxes Regulation Number PER-10/PJ/2025 concerning the Implementation of Information Exchange under International Agreements.
This regulation follows up on Article 13 of Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 39/PMK.03/2017 concerning Procedures for the Information Exchange under International Agreements, and PMK Number 70/2017 concerning Technical Guidance for Access to Financial Information for Tax Purposes.
The regulation comprises 14 articles across five chapters. The first chapter contains general provisions. The second chapter discusses the implementation of information exchange. The third chapter regulates the management and utilization of exchanged information. The fourth chapter includes the delegation of authority, and the fifth contains concluding provisions.
This regulation generally grants the DGT the authority to access, gather, and obtain tax-related information. It also identifies four primary sources of information that may be accessed by the DGT. First, tax or financial data related to a taxpayer’s rights and obligations. Second, information from government agencies, institutions, associations, and third-party entities. Third, economic data from financial institutions and similar entities in the context of financial information access for tax purposes. Fourth, other relevant tax or financial data obtained under DGT authority.
Additionally, the DGT is authorized to exchange such information with the competent authorities of partner countries or jurisdictions. The exchange can occur under three different mechanisms:
- request-based exchange of information;
- spontaneous exchange of information;
- automatic exchange of information.
Request-based exchange of information occurs when a partner jurisdiction formally inquires about specific tax-related information. This channel covers five data categories:
- identity and ownership details;
- accounting records;
- banking data;
- tax records;
- financial information.
If the requested data is unavailable in the DGT's systems, the DGT is entitled to request the information from financial institutions, taxpayers, or other relevant parties. The DGT may also initiate a tax audit to fulfill the request if necessary.
In the spontaneous exchange of information, the DGT shares tax information with partner countries or jurisdictions without being prompted by a request if the information is considered relevant to the partner's tax interests. Three types of information may be shared:
- transactions or activities involving Indonesian taxpayers and those in the partner country;
- tax rules and implementing regulations applicable in Indonesia or the partner country;
- other information deemed valid for taxation purposes in Indonesia or the partner country.
Automatic exchange of information refers to the periodic, systematic, and ongoing exchange of tax-related information between jurisdictions. Two types of data are typically included:
- information on tax withholding;
- other data relevant to tax compliance.
To carry out information exchanges, the regulation permits the DGT to conduct several activities to support international cooperation. These include competent authority meetings, tax examinations abroad, and simultaneous tax examinations. Competent authority meetings refer to formal discussions held between designated officials from Indonesia and its partner jurisdictions to address matters related to information exchange.
On the other hand, tax examinations abroad involve DGT representatives traveling to partner countries or jurisdictions to participate in audit or investigative activities conducted by the local tax authorities. Conversely, these activities may also include representatives from partner jurisdictions participating in tax examinations conducted in Indonesia.
Meanwhile, simultaneous tax examinations are conducted concurrently in Indonesia and one or more partner jurisdictions. Although carried out independently, these examinations are based on mutual agreement and are designed to collect and exchange relevant information.
Director General of Taxes Regulation Number PER-10/PJ/2025 officially took effect on May 22, 2025. Upon enactment, the regulation repeals four prior directives:
- Director General of Taxes Regulation Number PER-67/PJ/2009 concerning Procedures for the Information Exchange under Tax Treaties.
- Director General of Taxes Regulation Number PER-28/PJ/2017 concerning Procedures for Request-Based Exchange of Information under International Agreements.
- Director General of Taxes Regulation Number PER-24/PJ/2018 concerning Procedures for Spontaneous Exchange of Information under International Agreements.
- Director General of Taxes Regulation Number PER-02/PJ/2022 concerning Competent Authority Meetings, Tax Examinations Abroad, and Simultaneous Tax Examinations under International Agreements.
