Tax provisions governing the implementation of Coretax have once again been amended. The government has officially issued Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 1 of 2026 concerning the Fourth Amendment to PMK Number 81 of 2024 concerning Tax Provisions within the Coretax Administration System.
This amendment is intended to support the transformation of state-owned enterprises (SOEs) and the achievement of their strategic mandates through business restructuring initiatives.
As stated in the recital of PMK Number 1 of 2026, the amendment was introduced to adjust tax policies relating to the use of book value in the transfer and acquisition of assets for mergers, spin-offs, business expansions, and takeovers.
Definition Amendments Under Coretax Provisions
Revised Definition of SOE
In Article 1, Number 135, of PMK Number 81 of 2024, SOE was previously defined as a business entity with capital wholly or predominantly owned by the state through direct participation derived from separated state assets.
PMK Number 1 of 2026 revises this definition. SOE is now defined as a business entity that meets at least one of the following criteria:
- its capital is wholly or primarily owned by the Republic of Indonesia through direct participation; or
- it holds special rights reserved for the Republic of Indonesia.
Revised Definition of Minister
PMK Number 1 of 2026 also amends Article 1, Number 222. The definition of minister, which previously referred to the minister responsible for government affairs in the field of state finance, has been revised to refer to the minister responsible for government affairs in the field of finance.
Substantive Changes to Coretax Provisions
Approval for SOE Restructuring
Substantive amendments are introduced under Article 392, Paragraphs 7 and 8. Under the previous provisions, the use of book value for SOE business expansions or takeovers required approval from the minister responsible for SOE development affairs.
Under the amended provisions, asset restructuring relating to SOE business expansions or takeovers must instead obtain approval from the head of the government institution responsible for implementing SOE regulations, namely the Chief Executive Officer of Danantara.
Revision to the Business Continuity Period
Further amendments are set out in Article 393, Paragraph 2. Previously, taxpayers transferring or receiving assets as part of SOE mergers or acquisitions were required to continue their business activities for at least five years from the effective date of the merger, spin-off, or takeover.
Under the new regulation, this minimum continuity period has been reduced to four years. This change is expected to provide greater flexibility for SOEs in pursuing business expansion through mergers, acquisitions, or corporate restructuring.
Book Value Greater Flexibility
Additional flexibility is introduced through Article 405, Paragraph 4. Under the previous regime, if the Director General of Taxes granted approval for the use of book value but the requirements were later found not to have been met, the asset transfer had to be reassessed at market value as of the transfer date.
Under the amended provisions, taxpayers that fail to meet the formal requirements for using book value are no longer required to revalue assets to market value, provided the business purpose test is still satisfied.
Legal References
- PMK Number 81 of 2024 concerning Tax Provisions within the Coretax Administration System.
- PMK Number 1 of 2026 concerning the Fourth Amendment to PMK Number 81 of 2024 concerning Tax Provisions within the Coretax Administration System.
The various flexibilities introduced through these amendments to the Coretax provisions are expected to support accelerated economic and financial growth, particularly by optimizing SOE restructuring efforts in Indonesia.
Also Read:
https://ideatax.id/articles/per-19pj2025-beware-of-tax-invoice-access-deactivation
https://ideatax.id/articles/updates-to-the-05-msme-final-income-tax-and-its-business-impact
https://ideatax.id/articles/the-chart-of-accounts-for-coretax-reporting
