On February 14, 2025, the Minister of Finance issued Regulation Number 15 of 2025 (PMK-15) to update Regulation Number 17/PMK.03/2013 (PMK-17). PMK-15 simplifies and reorganizes previous regulations on tax audits to provide legal certainty.
Scope of Tax Audit
PMK-15 outlines three types of tax audits to verify compliance with tax obligations:
- Comprehensive tax audit thoroughly covers all items in the tax return and/or Tax Object Notification Letter (Surat Pemberitahuan Objek Pajak / SPOP).
- Focused tax audit thoroughly focuses on one or several items in the tax return and/or SPOP.
- Specific tax audit verifies compliance with tax obligations for specific items in the tax return and/or SPOP, data, or certain tax matters straightforwardly.
PMK-15 stipulates that tax compliance audits can cover multiple types of taxes and various tax periods. The types of taxes audited include income tax, VAT, luxury-goods sales tax, stamp duty, land and building tax, sales tax, carbon tax, and other taxes administered by the DGT. This regulation consolidates the audit rules for land and building tax and carbon tax.
Tax Audit Criteria
Tax audits serve two objectives. First, for compliance checking purposes, which is performed in the following situations:
- taxpayers apply for a tax refund due to overpayment, submit tax return stating an overpayment, report a loss, or have been granted a preliminary tax refund;
- taxpayers change the accounting year, accounting method, or re-evaluate fixed assets;
- taxpayers undergo consolidation, spin-off, division, liquidations, dissolutions;
- taxpayers plan to leave Indonesia permanently;
- taxable entrepreneurs do not make taxable deliveries of goods and/or services and have been given input tax refunds or have credited input tax; and
- taxpayers are selected for audit based on compliance risk, other parties failing to fulfill their obligations, concrete data showing unpaid or underpaid taxes, and discrepancies in land and building tax reports.
Second, for other purposes to implement the provisions of tax regulations, including:
- ex-officio granting or revocation of Taxpayer Identification Number (Nomor Pokok Wajib Pajak / NPWP), ex-officio confirmation of taxable entrepreneur, revocation of taxable entrepreneur confirmation, ex-officio registration of land and building tax objects, and revocation of Land and Building Tax Object Registration Certificate;
- resolution of objections, data collection for net income calculation norms, data matching, and determination of taxpayers located in remote areas or business locations in certain areas;
- determination of VAT payable location, settlement of tax collection, determination of the start of commercial operations or production related to tax facilities, determination of additional loss compensation periods, and fulfillment of information exchange based on international tax agreements;
- completion of joint agreement procedures, transfer pricing application, compliance assessment for the Financial Information Access Law, determination of costs at the exploration stage, and physical inspections for endorsements from other locations within the customs area to free trade zones and free ports; and
- collection or acquisition of data to expand the tax database, assessing other parties for obligations fulfillment, assessing tax facilities that have been provided, and other criteria to implement the provisions of tax regulations.
Tax Audit Period
The audit period for compliance checking purposes includes the testing period, as well as the closing conference and reporting period. The testing period is 5 months for a comprehensive tax audit, 3 months for a focused tax audit, and 1 month for a specific tax audit. This period is calculated from the date the Tax Audit Notification Letter is delivered until the Notification of Tax Audit Findings (Surat Pemberitahuan Hasil Pemeriksaan / SPHP) is delivered.
The testing period can be extended up to 4 months for taxpayers in one group or those involved in transfer pricing transactions and/or other specific transactions indicating financial transaction manipulation. If an extension is carried out, officials at the Tax Audit Unit must notify the taxpayer.
After testing, the closing conference and reporting period is a maximum of 30 working days from the date the SPHP is delivered until the Audit Report (Laporan Hasil Pemeriksaan / LHP) is delivered. For specific tax audits of concrete data, the audit must be completed within 10 working days for each testing as well as the closing conference and report process, so the audit is completed within 20 days at the latest. Meanwhile, the audit period for other purposes is a maximum of 4 months from the date the Tax Audit Notification Letter is delivered until the LHP is delivered.
Other Key Changes
PMK-15 introduces temporary findings discussion between tax auditors and taxpayers. Tax auditors must conduct a temporary findings discussion and deliver a list of audit findings in the SPHP, except for specific tax audits.
Another new provision is regarding audit suspension and resumption. If the audit progresses to the stage of preliminary evidence audit or tax crime investigation, the tax auditor must issue notification letters for both the suspension and resumption of the audit.
One of the tax auditors’ authorities is related to electronic data management and access. Tax auditors are authorized to access and/or download electronic data related to audit purposes. Tax auditors are also authorized to enter and inspect places or spaces, movable goods, and/or immovable goods deemed necessary for the inspection. These places include those used to store books, records, and/or documents, including electronic data used for bookkeeping or recording. They can also inspect other places used to store documents, money, and goods.
A crucial change is the shorter tax audit period, which makes the temporary findings discussion feasible. PMK-15 requires taxpayers to provide a written response to the SPHP and a list of audit findings within a maximum of 5 working days from the time the SPHP is received.
