In its recent annual report, the Directorate General of Taxes (DGT) highlighted a significant increase in the number of corporate and individual taxpayers audited in 2023. Out of 1,665,826 corporate taxpayers required to file a tax return, 40,513 were audited. Similarly, 11,783 individual taxpayers were audited out of the 3,576,340 required to file. This resulted in an overall audit coverage ratio (tax ratio) of 1% for the year. The details are as follows:
Compared to the previous year, the tax ratio has increased. In 2022, Indonesia's tax ratio was just 0.88% (DGT, 2023), and in 2021, it was 0.86% (DGT, 2022).
This rise in audit coverage aligns with stronger enforcement measures, including sealing, as stipulated in Minister of Finance Regulation (Peraturan Menteri Keuangan / PMK) Number 17 of 2013 on audit procedures. These provisions were later updated under PMK Number 15 of 2025 on tax audits.
Sealing refers to the official act of placing a seal on a specific place or space, movable and/or immovable property, including data storage media, electronically managed data access, and other objects that are used or are allegedly used to store books, records, documents, including electronic data and other relevant objects.
Authorities may implement sealing during an audit under the following circumstances:
- First, the taxpayer, representative, or taxpayer proxy does not allow tax auditors to enter and inspect the place or space, movable and/or immovable properties necessary, including those used to store books, records and/or documents, and electronic data used for bookkeeping or recording, storing documents, saving money and/or storing goods that can provide clues about the income earned, business activities, freelance work, objects subject to tax, or anything related to the audit purpose.
- Second, the taxpayer, representative, or taxpayer proxy refuses to assist the audit process, which includes denying access to electronic data or movable and/or immovable property.
- Third, the taxpayer, representative, or taxpayer proxy is not present.
To enforce sealing, auditors must be accompanied by at least two adult witnesses. The process must be documented in a sealing report, signed by both the auditor and the witnesses. If witnesses refuse to sign, auditors must note this in the report. Furthermore, taxpayers can file a lawsuit if a seal is placed without proper documentation.
Although the auditor has the authority to impose sealing, it can be lifted under the following conditions:
- First, the taxpayer, representative, or taxpayer proxy permits tax auditors to access or enter a sealed place or space, movable and/or immovable properties, and/or assist the audit process.
- Second, tax auditors determine that sealing is no longer required.
- Third, investigators request unsealing in connection with a criminal tax investigation.
Like the sealing process, unsealing must also be witnessed by at least two adults and documented in an unsealing report.
Taxpayers are prohibited from damaging, removing, or interfering with the seal. Additionally, they cannot alter, delete, or move books, records, and/or documents, including electronic data stored in specific places or spaces, as well as movable and/or immovable properties, including sealed data storage media. If a seal is found damaged or removed, auditors are required to report the incident to the police. Therefore, taxpayers must be careful with the seal to prevent damages.
If seven days pass after sealing and the taxpayer, representative, or taxpayer proxy still does not grant the auditor access to the sealed place or space, movable and/or immovable properties, and/or does not provide cooperation, they will be deemed unwilling to comply with the audit. As a result, the auditor will proceed with the audit based on the available data, disregarding any unsubmitted records from the taxpayer.
If a taxpayer’s property—movable or immovable—is subject to sealing, taxpayers should:
- First, ensure all requested documents and data are provided to auditors.
- Second, present a valid explanation with supporting evidence if they are unable to provide the requested documents and data.
- Third, verify that sealing is conducted for legitimate reasons, with proper documentation and witnesses.
- Fourth, ensure the unsealing process is accompanied by two witnesses and documented in the report.
- Fifth, do not damage or remove the seal. Intentional tampering with a seal can result in legal consequences under Article 232 of the Criminal Code.
This concludes the explanation regarding sealing in audits. For further assistance, Ideatax is ready to help.
References
- DJP. (2022). 2021 Annual Report: Contributing Together to National Economic Recovery. Jakarta: DGT.
- DJP. (2023). 2022 Annual Report: Together in the Spirit of Reform, Making Excellent Performance a Tradition. Jakarta: DGT.
- DJP. (2024). Annual Report 2023. Jakarta: DGT.
- OECD. (2006). Strengthening Tax Audit Capabilities: General Principles and Approach. Paris: OECD.
- Rabiyah, U. (2015). The Influence of Examination and Implementation of Self Assessment System on Increasing Taxpayer Compliance at KPP Madya Makassar. Nobel Journal.
