The Directorate General of Taxes (DGT) recorded that 16,905 taxpayers have not yet implemented the Global Minimum Tax, which requires an effective tax rate of at least 15%.
The Directorate General of Taxes (DGT) of the Ministry of Finance recorded that 5,757 taxpayers, or around 25% of the total 22,662 taxpayers identified as falling under the scope of the Global Minimum Tax (GMT), have officially implemented the international tax regulation as of October 22, 2026.
Director General of Taxes Bimo Wijayanto stated that 22,662 taxpayers from 1,988 corporate groups were identified as potentially subject to the GMT. Consequently, 16,905 taxpayers have not yet been recorded as implementing the provision.
"We recognize that preparation certainly requires detailed coordination within corporate groups and a clear understanding of the new regulations," Bimo said during a briefing at the DGT headquarters on Wednesday (October 28, 2026).
DGT urges companies indicated to be within the scope of GMT to verify their status and coordinate with their respective corporate groups to prepare the necessary data and fulfill their tax obligations.
Companies are also advised to pay attention to their payment obligations if any additional tax is owed. For the 2025 fiscal year, corporate groups operating on a calendar fiscal year face a payment deadline of December 31, 2026, for any top-up tax.
GMT is part of Pillar Two in the two-pillar solution developed by the Organization for Economic Co-operation and Development (OECD) alongside G20 member countries to address tax challenges arising from the globalization and digitalization of the economy.
The policy aims to ensure that qualifying multinational enterprise (MNE) groups are subject to a minimum effective tax rate (ETR) of 15% on profits generated in each jurisdiction where they operate.
This regulation does not apply unconditionally to all multinational enterprises. Under the Global Anti-Base Erosion (GloBE) rules, these provisions generally apply to MNE groups with annual consolidated revenues of at least EUR 750 million in at least two of the four fiscal years preceding the tested tax year, subject to applicable scope and exclusion rules.
Under the GMT mechanism, if an MNE group's ETR in a given country falls below 15%, a top-up tax will be levied to cover the difference (gap) up to the 15% minimum threshold. The implementation of GMT aims to curb the tax competition known as the "race to the bottom."
GMT does not prohibit countries from setting domestic corporate tax rates below 15%. However, for MNE groups within the scope of these rules, tax incentives that reduce the ETR below 15% could trigger a top-up tax under GloBE rules, potentially reducing the effectiveness of such incentives.
In Indonesia, GMT provisions are regulated under Minister of Finance Regulation (PMK) Number 136 of 2024 concerning the Imposition of Global Minimum Tax Based on International Agreements. Meanwhile, procedures for exercising tax rights and fulfilling tax obligations related to GMT are further detailed in Director General of Taxes Regulation No. PER-6/PJ/2026.
Domestic Minimum Top-up Tax (DMTT) and Income Inclusion Rule (IIR) provisions took effect on January 1, 2025, while the Undertaxed Profits Rule (UTPR) took effect on January 1, 2026.
Also Read:
Global Minimum Tax: Don’t Wait Until Year-End
DGT Records 5,581 Taxpayers Under Global Minimum Tax Scheme
OECD Revisi GIR dan Perketat Implementasi Pajak Minimum Global
Writer: Fiorentina Renata Trixie | Editor: Thomas Rizal
