Knowing the Types of Trigger Data in SP2DK

Knowing the Types of Trigger Data in SP2DK


06 Jun, 2024 09:06 WIB

At the end of 2023, the Audit Board or Badan Pemeriksa Keuangan (BPK) reported that the trigger data derived by the DGT Head Office to the Tax Service Office or Kantor Pelayanan Pajak (KPP) through Approweb was not entirely valid. The three trigger data include the corporate taxpayer purchases matching with VAT input tax, the equalization of salary costs with Income Tax Article 21 expenses, and the equalization of interest expenses with Income Tax Article 23, Income Tax Article 26, or Final Income Tax Article 4(2).

The comparison between corporate taxpayer purchases and VAT Input Tax is often invalid because corporate taxpayers argue that they purchase supplies and equipment from UMKMs that are not liable to be confirmed as Taxable Entrepreneurs (PKP). In addition, taxpayers who receive uncollected VAT facilities do not report all purchases as input tax in the VAT Monthly Return because taxpayers who receive VAT facilities cannot credit their input tax. This issue causes the triggering data of the equalization of VAT input tax with purchases of corporate taxpayers to be invalid.

However, the comparison of Income Tax Article 21 with salary costs is also often considered to have low validity because the Periodic Income Tax Return Article 21 reported by the taxpayer does not reflect the cost of salary costs incurred by the taxpayer. In addition, taxpayers often include salary/wage costs in others, such as rent, entertainment, and more.

Furthermore, the equalization of interest expense with Income Tax Article 23, Income Tax Article 26, or Final Income Tax Article 4(2) is assumed to have low validity because corporate taxpayers often directly borrow through banks that are not subject to Income Tax Article 23, Income Tax Article 26 or Final Income Tax Article 4(2). Note that the interest income received by the bank is not deducted by income tax. The bank deposits the interest income itself.

These types of trigger data are a small portion of the trigger data that DGT provides to tax offices through the Approweb information system. The Audit Board (BPK) stated that the lack of validity of the trigger data is because DGT has not been optimal in evaluating and testing the validity of the trigger data.

In the Circular Letter of the Director General of Taxes Number SE-49/PJ/2016 on Taxpayer Monitoring Through Information System, among others, it is stipulated that trigger data is an overview of the overall data comparison results that indicate the existence of taxpayer non-compliance both formally and materially.

Trigger data is obtained from the data comparison results in the information system, including asset, liability, capital, business income or turnover, and tax credit data. Trigger data is followed up by account representatives through the issuance of SP2DK or Surat Permintaan Penjelasan atas Data dan/atau Keterangan.


When first issued in 2026, the trigger data was only limited to the financial statement data equalization with tax reporting data reported by taxpayers in the DGT information system. Along with the development of transactions, Approweb data has evolved to match internal DGT data with data reported by other parties through the ILAP or Instansi Pemerintah, Lembaga, Asosiasi, dan Pihak Lain mechanism (Government Agencies, Institutions, Associations, and Other Parties).

Currently, trigger data has developed rapidly. Especially with the implementation of the coretax system, more and more data and information received by DGT to be processed into trigger data. In fact, in the future, the development of trigger data will be based on Artificial Intelligence (AI), Compliance Risk Management (CRM), and Business Intelligence (BI). Some trigger data that can be identified are as follows:

  1. Equalization of sales with VAT delivery, 
  2. Equalization of purchase with input tax in Periodic VAT Return, 
  3. Equalization of salary expenses with Periodic Income Tax Return Article 21, 
  4. Equalization of rental costs with Periodic Income Tax Return Article 23/Income Tax Article 26/Income Tax Article 4 (2), 
  5. Equalization of service fees with Periodic Income Tax Return Article 23/Ph Article 26/Ph Article 4(2), 
  6. Equalization of transportation costs with Periodic Income Tax Return Article 23/PPh Article 26/PPh Article 4(2), 
  7. Equalization of royalty costs with Periodic Income Tax Return Article 23/Ph Article 26.
  8. Equalization of marketing/promotion expenses with Periodic Income Tax Return Article 23/Ph Article 26.
  9. And so on.

The Directorate General of Taxes has many types of trigger data. However, one thing to remember is that the trigger data in the letter of request for data and information explanation (SP2DK) must be followed up by the taxpayer within 14 working days from the issuance date of the SP2DK. The Tax Authority may continue the taxpayer's compliance supervision with a tax audit if the taxpayer does not respond to SP2DK within the given period.

Also Read: Tips in Dealing with SP2DK

Therefore, to avoid mistakes in responding to the trigger data that leads to a tax audit, taxpayers can consult with Ideatax.