The Ministry of Finance’s decision to postpone Article 22 income tax collection on online marketplace transactions gives many digital businesses more time to prepare before the policy takes effect. For the government, the delay also provides an opportunity to refine the policy and improve public communication.
Minister of Finance Purbaya Yudhi Sadewa said the decision was made to safeguard public purchasing power and allow the ongoing economic recovery to continue. Under the revised timeline, enforcement of Minister of Finance Regulation Number 37 of 2025 has been postponed until the end of October 2026, with the new tax collection scheme scheduled to take effect on November 1, 2026.
The appointment of Tokopedia, Shopee, Lazada, and Blibli as Article 22 income tax collectors has also been temporarily revoked, while collected taxes will be refunded to merchants.
The delay provides a valuable opportunity to evaluate the policy and ensure a seamless rollout when it eventually takes effect. It gives the government, marketplaces, and businesses extra time to enhance their operational readiness and optimize policy communication.
The marketplace tax policy does not introduce a new type of tax. Rather, it changes when and how the tax is collected, with marketplaces collecting the tax earlier in the transaction process. The tax collected can also still be credited against the taxpayer’s final tax liability.
However, bringing forward the timing of tax collection means businesses may experience a temporary reduction in cash flow at the beginning of a transaction. Businesses and marketplaces will also need to adjust their administrative processes because the tax will be collected upfront.
The change may feel more burdensome for marketplace businesses since taxes have generally been paid at a later stage.
Supporting the Digital Ecosystem
The delay gives the digital commerce ecosystem more time to grow without having to absorb new administrative requirements rapidly. It may also ease concerns among businesses about the introduction of tighter tax monitoring on online platforms.
The digital ecosystem is constantly evolving. By deferring the measure, businesses are not immediately required to take on additional administrative obligations, allowing them more room to grow.
At the same time, the delay also means that the Directorate General of Taxes’ efforts to obtain more reliable transaction data from merchants for monitoring tax compliance among digital businesses will be put on hold.
A Level Playing Field
The government has said that the changes to marketplace tax collection are intended to create a level playing field between online and offline merchants. However, the proposed mechanism may still require further consideration to ensure that both groups receive genuinely equitable tax treatment. This is because offline transactions are not generally subject to the same Article 22 income tax collection proposed for marketplace transactions.
For offline transactions, not every transaction is subject to tax withholding or collection. Article 23 income tax and Article 4(2) final income tax may apply to services and rental transactions, while Article 22 income tax applies only to specific commodities or transactions. Online transactions made through marketplaces, by contrast, may be subject to Article 22 income tax more broadly. As a result, substantively similar transactions could receive different tax treatment merely because one takes place through a marketplace.
The situation could create additional administrative requirements for digital businesses. Although the tax collected can be credited, sellers will still need to adjust their administrative processes and absorb the resulting cash flow impact from the outset. Offline merchants, meanwhile, do not face the same burden.
Tax Refunds
Following the postponement of the policy until November 1, 2026, Minister of Finance Purbaya also stated that they will refund taxes already collected. The process should be relatively straightforward as marketplace transactions are digitally recorded.
Since the transactions are digitally documented, marketplaces should be able to manage the refund process efficiently. Sellers whose transactions were subject to tax collection can be readily identified, meaning refunds would not require an overly complex process. The fact that the tax filing return period has not yet begun should also make the necessary administrative adjustments rather simple.
Until the revised policy takes effect, the government could make greater use of the tax authority’s existing digital data capabilities. Data exchanges with marketplaces, data analytics, and technology-based compliance monitoring could complement the marketplace tax collection policy.
The approach would enable the digital ecosystem to continue growing without placing excessive upfront administrative burdens on businesses. By combining data-driven tax administration with a measured implementation process, the government can continue to fortify tax compliance whilst maintaining a supportive environment for digital businesses.
Also Read:
Complete List of Tax Account Codes and Tax Payment Type Codes for e-Billing
DGT Regulation Number 11 of 2025
Breaking Down the Article 21 Withholding Tax Provisions