The Directorate General of Taxes (DGT) uses requests for explanation of data and/or information (surat permintaan penjelasan atas data dan/atau keterangan/SP2DK) as one of its instruments for monitoring taxpayers’ material compliance. Through the Core Tax Administration System (Coretax), tax monitoring increasingly relies on the integration and matching of data from various sources.
However, SP2DK findings are not always accompanied by details of the underlying transactions. In some cases, taxpayers receive only an aggregate figure indicating a discrepancy between DGT data and the information reported in their tax returns. This creates challenges when taxpayers are required to explain the discrepancy or amend their tax returns (surat pemberitahuan/SPT).
Without transaction-level details, taxpayers must trace the source of the discrepancy themselves before determining the appropriate course of action. If an amendment is made without adequate reconciliation, the risk of reporting errors and miscalculating tax liabilities may increase.
Aggregate Findings
Taxpayer compliance monitoring is governed by Minister of Finance Regulation No. 111 of 2025 (PMK 111/2025), with technical guidance provided under Circular Letter of the Director General of Taxes No. SE-8/PJ/2026 (SE-8/PJ/2026). Monitoring is conducted through material compliance review (penelitian kepatuhan material/PKM) to assess whether taxpayers have fulfilled their tax obligations.
If a PKM identifies anomalies or indications of noncompliance, the head of a tax service office (kantor pelayanan pajak/KPP), through an account representative (AR), may issue an SP2DK. The clarification and data review process between the taxpayer and the DGT is documented in the minutes of the implementation of a request for explanation of data and/or information (berita acara pelaksanaan permintaan penjelasan atas data dan/atau keterangan/BAP2DK).
Under data-driven tax monitoring, Coretax relies on the integration and matching of information from various sources, including government agencies, institutions, associations, and other parties (ILAP), banks, customs documents, and third-party reports. Systems such as compliance risk management (CRM) and web-based profile application (Aplikasi Profil Berbasis Web/Approweb) process this information to identify potential noncompliance. The results may be presented using exposure codes, such as 2-1 and 2-2.
Problems arise when an SP2DK states only the total value of the findings without providing transaction-level details or a transaction log. Taxpayers cannot immediately identify which transactions caused the discrepancy, the period in which it occurred, or the basis for calculating the amount in question.
As a result, taxpayers must reconcile DGT data with their accounting records, transaction documents, and previously filed tax returns. If the findings cover numerous transactions or multiple tax periods, tracing the discrepancies may require additional time and resources.
An SP2DK is a tax monitoring instrument, not a tax assessment letter. Therefore, the findings it contains need to be clarified before taxpayers determine how to proceed. If the clarification process reveals an underpayment, taxpayers must assess whether an amendment is required and settle their obligations in accordance with applicable tax regulations.
Risks of Amending Tax Returns
When SP2DK findings are not accompanied by transaction-level details, amending an SPT becomes more complex. Taxpayers must ensure that the amounts reported reflect actual transactions and are supported by adequate documentation.
Article 8 paragraph (1) of the General Provisions and Tax Procedures Law (UU KUP) allows taxpayers to voluntarily amend their tax returns by submitting a written statement, provided that the DGT has not yet commenced a tax audit. If the amendment increases the tax payable, administrative sanctions in the form of interest may apply in accordance with the prevailing regulations.
The risks associated with amendments warrant greater attention following the introduction of the replacement mechanism (replace) in Coretax. Director General of Taxes Regulation No. PER-12/PJ/2026, which took effect on October 1, 2026, governs tax return amendments under this mechanism and replaces the previous provisions under PER-11/PJ/2025.
Under the replace mechanism, the latest amended SPT supersedes the previous return as the basis for reporting for the relevant tax period. Coretax recalculates the tax liability based on the amended return while taking into account tax payments already made for that period.
In cases involving SP2DK findings without transaction-level details, taxpayers should pay particular attention to three main risks. First, errors in amended return data. Aggregate figures cannot always be used directly to complete an amended SPT. Taxpayers must identify the transactions underlying the findings and ensure that the reported data comply with applicable regulations and Coretax reporting requirements. Incomplete data or invalid third-party identification details may create reporting difficulties.
Second, changes in tax refund positions. Amending an SPT may affect tax calculations and the taxpayer’s overpayment position. If a company has a pending tax refund claim, the implications of the amendment should be assessed before the revised return is filed to ensure that any changes in data and calculations can be properly substantiated.
Third, changes in carryforward balances. An amendment may affect tax credit balances carried forward and used in subsequent tax periods. Companies must therefore calculate the impact on both the amended period and subsequent periods.
These three risks indicate that taxpayers should not amend their SPTs solely on the basis of aggregate figures stated in an SP2DK. Any amendment should be preceded by transaction tracing, data reconciliation, and a comprehensive assessment of the tax implications.
Mitigation Measures
Taxpayers should ensure that their responses to SP2DKs are supported by traceable data. The first step is to reconcile the DGT’s findings with accounting records, tax returns, and internal transaction documents. The objective is to identify the source of the discrepancy and determine whether it reflects a reporting error or requires further explanation.
If an SP2DK contains only aggregate figures, taxpayers may submit a written request to their AR for clarification regarding the calculation basis, types of data used, relevant periods, and underlying transaction details. This information is necessary to enable taxpayers to respond accurately and assess whether an SPT amendment is required.
Responses should ideally be supported by a reconciliation matrix, general ledger extracts, transaction documents, and other relevant evidence. If discrepancies arise between DGT data and internal records, taxpayers should explain the reasons for those differences based on the available supporting documentation.
If an internal review identifies an underpayment, companies should calculate the impact of the amendment on tax payable, payments already made, tax refunds, and carryforward balances. The calculation should cover the relevant tax period and any subsequent periods that may be affected before the amended SPT is submitted through Coretax.
Companies should also strengthen their tax data controls by adjusting their enterprise resource planning (ERP) systems, maintaining adequate transaction documentation, and conducting regular reconciliations between accounting records and tax filings. For complex cases, particularly those involving transactions across multiple periods, differing interpretations of tax regulations, or tax refund risks, companies may consider seeking assistance from a licensed tax consultant in accordance with applicable requirements.
SP2DK findings without transaction-level details do not automatically mean that taxpayers must amend their SPTs. They need to understand the basis of the findings, trace the underlying transactions, and evaluate the tax implications before determining the appropriate course of action.
If you need assistance responding to an SP2DK, tracing tax findings, or assessing the risks of amending tax returns through Coretax, Ideatax’s tax consulting team is ready to help you determine the appropriate steps in accordance with applicable tax regulations.
Also Read:
Understanding SP2DK: Purpose, Process, and How to Respond
SP2DK Recording Rights and Procedural Fairness
Tax Refunds Are a Right, Not a Fiscal Favor
Editor: Thomas Rizal
