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Tax Brief: PMK Number 53 of 2025

 

The Law of the Republic of Indonesia Number 7 of 2021 concerning the Harmonization of Tax Regulations has now been in effect for 4 years. Under this law, the government and the House of Representatives agreed to raise the value-added tax (VAT) rate from 10% to 11%, effective April 2022. It was also decided that the VAT rate would be increased again to 12% no later than January 2025.

 

However, considering Indonesia’s economic and socio-political conditions, the government has decided to keep the effective VAT rate unchanged in 2025. This is because the tax base applied is 11/12 of the transfer or replacement value. As a result, while the statutory VAT rate is technically 12%, the effective rate remains at 11%. This provision was outlined in Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 11 of 2025 concerning Other Values as the Tax Base and Specific Value-Added Tax Rate.

 

In August 2025, the government amended PMK Number 11 of 2025 through PMK Number 53 of 2025, making changes to the PMK Number 11 of 2025 concerning Other Values as the Tax Base and Specific Value-Added Tax Rate.

 

According to its recital, one reason for the amendment is to provide legal certainty for cryptoasset trading transactions and to reflect developments in the cryptoasset market. As such, adjustments to the VAT provisions on cryptoasset trading were considered necessary.

 

PMK Number 53 of 2025 introduces two main changes. First, PMK Number 53 of 2025 repeals Article 343 of PMK Number 81 of 2024, as amended by PMK Number 11 of 2025. Article 343 of PMK Number 81 of 2024 had set out the following rules:

  • If the electronic trading system provider is also a physical cryptoasset trader, the specific VAT base is calculated as 1%, multiplied by 11/12 of the VAT rate, and then multiplied by the transaction value.
  • If the electronic trading system provider is a non-physical cryptoasset trader, the specific VAT base is 2%, multiplied by 11/12 of the VAT rate, and then multiplied by the transaction value.
  • The transaction value means:
  • the amount paid by cryptoasset buyers, if the cryptoasset transaction is in fiat currency;
  • the value of each cryptoasset exchanged, if it is a crypto-to-crypto swap; or
  • the value of cryptoassets transferred, if exchanged for non-crypto goods and/or services.
  • If the cryptoasset transaction involves foreign currency, the value is converted to IDR at the exchange rate set by the Minister at the time VAT is collected.
  • For swaps or transfers of cryptoassets, the value is determined by either the futures exchange facilitating the trade or the system used by the trading platform, applied consistently across all transactions.

     

Second, PMK Number 53 of 2025 repeals Article 354 of PMK Number 81 of 2024, as amended by PMK Number 11 of 2025. Article 354 of PMK Number 81 of 2024 regulates the following matters:

  • For cryptoasset verification and/or mining pool services provided by cryptoasset miners, the VAT is calculated at 10%, multiplied by 11/12 of the VAT rate, and then multiplied by the monetary value of cryptoassets received by the miners.
  • If payment received by cryptoasset miners is in a foreign currency, it is converted to IDR at the official exchange rate set by the Minister of Finance.
  • If payment received by cryptoasset miners is in cryptoassets, the value is converted to IDR and determined by the relevant futures exchange or by the miners’ system.

     

The repeal of Articles 343 and 354 of PMK Number 81 of 2024, as amended by PMK Number 11 of 2025, reflects the fact that VAT on cryptoasset transactions is now comprehensively governed under PMK Number 50 of 2025 concerning Value-Added Tax and Income Tax on Cryptoasset Trading Transactions.

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