Establishing the Indonesia International Financial Center (Pusat Finansial Internasional Indonesia/PFII) requires comprehensive readiness across various aspects, from policies and regulations, infrastructure, and technology to the business ecosystem and human resources. All these aspects must be prepared in an integrated manner so PFII can attract global investment and compete with other international financial centers, such as Singapore and Dubai.
Ideatax Managing Partner Jonathan Nainggolan assessed that the PFII regulation issued by the government through Law Number 6 of 2026 is merely the initial foundation. The program's success will depend heavily on policy implementation and the readiness of supporting facilities on the ground.
According to Jonathan, the government needs to ensure professional PFII management, including through a transparent official appointment process, to maintain global investor trust.
“Global investors consider not only special tax regimes but also various other supporting aspects, such as the readiness of physical infrastructure, technology, business facilities, transportation, and the environment where they operate,” Jonathan said on Friday (Nov 6, 2026).
The tax expert from Ideatax explained that Singapore and Dubai could develop as international financial centers because they are supported by mature infrastructure and business ecosystems. Therefore, the government needs to ensure the PFII location has facilities that meet investors' needs.
If PFII is developed in the Bali area, the government needs to accelerate the construction of office buildings, housing, public transportation, health facilities, and security. Such infrastructure is essential to support investments, especially cross-border wealth management through family offices and trust funds. Investors in this sector consider not only yields but also the quality of life for their families who will settle there long term.
Meanwhile, developing PFII in Jakarta offers an advantage in terms of business infrastructure. However, the government needs to establish clear regional boundaries and regulate the separation of business activities inside and outside PFII.
"Companies operating inside PFII while also having business activities outside the zone should not be allowed to treat all their income as eligible for the special tax scheme," Jonathan Nainggolan explained.
The tax practitioner from Ideatax emphasized the importance of consistently applying the ring-fencing principle when implementing the special tax regime. Under this principle, the special tax scheme can be used only for income generated from business activities that meet PFII criteria, while income from business activities outside the zone must be separated in the bookkeeping.
This provision needs clarification, especially for supporting service companies such as tax consultants, fund managers, and other professional service providers. The government needs to establish criteria for determining income sources and the mechanism for income allocation for companies operating both inside and outside the zone.
In addition, Jonathan stated that the government needs to clarify the classification and requirements for granting special tax schemes to both primary and supporting service activities through implementing regulations. Primary service activities, such as banking and family office management, could receive long-term special tax schemes. However, technical details on the types of facilities, requirements, and the duration of their provision still need clarification, including for supporting service activities.
"What must be ensured is how the provisions regarding primary and supporting services are elaborated in the implementing regulations, including the requirements, the scope of the special tax scheme, and the duration of its provision," he said.
Further provisions on the implementation of the PFII Law will be regulated through implementing regulations. Article 72 of the PFII Law mandates that these regulations be stipulated no later than six months after the law's enactment on August 19, 2026, which falls on February 19, 2027.
Meanwhile, the Ideatax managing partner reminded investors to account for the Global Minimum Tax (GMT) provisions. These provisions set a minimum effective tax rate of 15% for multinational enterprise groups with consolidated revenues of at least EUR 750 million.
PFII tax incentives do not automatically exempt companies from GMT obligations. If the incentives cause the effective tax rate to fall below 15%, enterprise groups meeting the GMT criteria could potentially be subject to a top-up tax.
"Investors must first calculate whether the special tax scheme provided in PFII truly offers benefits after taking the GMT rules into account," Jonathan emphasized.
Besides taxation instruments, Jonathan also praised the non-physical institutional support offered by PFII, which includes the Golden Visa facility and the involvement of ad hoc judges in resolving civil and business disputes.
"What matters most is how the special provisions in PFII can be applied clearly and harmoniously with applicable tax regulations, thereby providing certainty for investors while maintaining orderly tax administration," concluded the Ideatax Managing Partner.
Also Read:
Tax Brief Law Number 6 of 2026: PFII Tax Incentives and Their Implications
PFII Law Regulates Up to 100% Corporate Income Tax Incentives for Investors
Jakarta and Bali Set as PFII Locations, Indonesia Eyes Financial Hub Status
This article was published on Beritasatu.com under the title “Pengembangan PFII Perlu Didukung Kesiapan Ekosistem Bisnis”
Editor: Thomas Rizal
