Tax Brief: PMK Number 52 of 2025 Second Amendment to PMK Number 48 of 2023
The government has updated income tax and VAT rules on gold sales and deliveries. Through Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 52 of 2025, the government enacted a second amendment to PMK Number 48 of 2023 concerning Income Tax and/or Value-Added Tax on the Sale/Delivery of Gold Jewelry, Gold Bullion, Non-Gold, Non-Gemstone, and/or Other Non-Precious Jewelry, and Related Services Conducted by Gold Jewelry Manufacturers, Traders, and/or Bullion Businesses.
The amendment in PMK Number 52 of 2025 focuses solely on one provision, i.e., Article 5, Paragraph 2, of PMK Number 48 of 2023. Specifically, the change in Letter c stipulates that Article 22 income tax will not be collected on the sale of gold bullion made by gold jewelry and/or gold bullion businesses to financial services institutions that are licensed by the Financial Services Authority (Otoritas Jasa Keuangan/OJK).
Previously, there was no explicit exemption from Article 22 income tax for such transactions with licensed bullion banks.
Notably, under Law of the Republic of Indonesia Number 4 of 2023 concerning the Development and Reinforcement of the Financial Sector, the government defines bullion business activities as financial services involving gold, including savings, financing, trading, custody, and other bullion-related services, carried out by financial services institutions. To operate in this space, financial services institutions must be licensed by the OJK.
Further details are outlined in OJK Regulation Number 17 of 2024 concerning the Implementation of Bullion Business Activities, which defines five specific types of bullion services, including:
Gold Savings
Gold savings refer to the safekeeping of standardized gold amounts entrusted by the public to licensed financial services institutions under a mutual agreement.
Gold Financing
Gold financing involves the provision of standardized gold by a financial services institution under an agreement that requires repayment of the same amount at a later date, along with compensation or profit-sharing arrangement.
Gold Trading
Gold trading refers to buying and selling standardized gold under an agreement between parties, not intended for custody and/or financing.
Gold Custody
Gold custody involves holding gold on behalf of the public, where the financial services institution earns service-based fees under a contractual arrangement.
- Other bullion-related services carried out by financial services institutions.
Additionally, the OJK requires that bullion used in these activities meet the Indonesian National Standard or internationally recognized standards, issued by authorized standardization institutions.
PMK Number 52 of 2025 was introduced to improve legal certainty, fairness, and administrative convenience for income tax purposes related to bullion transactions. It confirms that the transfer of gold bullion to licensed bullion banks is exempt from income tax under Article 22. Importantly, this exemption does not require a specific tax exemption certificate for the transaction to apply.
This is a brief explanation of PMK Number 52 of 2025. If you are engaged in bullion activities and need tailored tax planning, Ideatax is ready to assist.
Legal References
- Law of the Republic of Indonesia Number 4 of 2023 concerning the Development and Reinforcement of the Financial Sector.
- Financial Services Authority Regulation Number 17 of 2024 concerning the Implementation of Bullion Business Activities.
Minister of Finance Regulation Number 52 of 2025 concerning the Second Amendment to the Minister of Finance Regulation Number 48 of 2023 concerning Income Tax and/or Value-Added Tax on the Sale/Delivery of Gold Jewelry, Gold Bullion, Non-Gold, Non-Gemstone, and/or Other Non-Precious Jewelry, and Related Services Conducted by Gold Jewelry Manufacturers, Traders, and/or Bullion Businesses.