Tax Brief: PMK Number 54 of 2025 - Third Amendment to PMK Number 81 of 2024
Less than a year after it took effect, the Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 81 of 2024 concerning Tax Provisions Related to the Coretax System has already undergone three rounds of amendment.
Through PMK Number 54 of 2025, the government introduces several substantive changes to PMK Number 81 of 2024. According to the recital, the amendments aim to provide greater legal certainty and to adapt to developments in the bullion and gold bar import industries, as well as cryptoasset trading. Adjustments to the tax treatment of these activities are considered necessary.
Another reason for revising PMK Number 81 of 2024 is that the taxation on cryptoasset trading set out in the regulation was not fully aligned with the Coretax administration system. This misalignment prompted the government to amend the rules. The main changes are as follows:
First, PMK Number 54 of 2025 removes Article 1, Numbers 199 to 206 of PMK Number 81 of 2024. These provisions defined terms related to cryptoassets, such as electronic means, cryptoasset sellers, cryptoasset miners, physical cryptoasset traders, cryptoasset buyers, and documents deemed equivalent to unified withholding/collection slips.
Second, PMK Number 54 of 2025 removes Articles 217 to 225 of PMK Number 81 of 2024. These articles governed Article 22 income tax collection on payments for the delivery of goods and activities in the import sector or other business sectors. In effect, PMK Number 54 of 2025 eliminated Part Five of Chapter VI of PMK Number 81 of 2024.
Third, PMK Number 54 of 2025 removes Articles 340 to 369 of PMK Number 81 of 2024. These provisions covered value-added tax (VAT) and income tax on transactions involving cryptoasset trading. Their removal follows the issuance of PMK Number 50 of 2025 concerning Value-Added Tax and Income Tax on Cryptoasset Trading Transactions.
Fourth, PMK Number 54 of 2025 removes Article 465, Letter w of PMK Number 81 of 2024. This article outlined procedures for collecting Article 22 income tax on payments for the delivery of goods and for import/export activities involving coal, metal minerals, and non-metal minerals by license holders, as well as related exemption procedures as referred to in Article 219, Paragraph 3. Since Articles 217 to 225 have been removed, the procedures outlined in Article 465, Letter w, of PMK Number 81 of 2024 are no longer applicable.
Fifth, PMK Number 54 of 2025 removes Article 469, Letter l, of PMK Number 81 of 2024. This provision contained examples of VAT as referred to in Article 343, Paragraph 1, and Article 22 income tax calculations for cryptoasset sales and purchases, as referred to in Article 358, Paragraph 9, and listed in the Appendix OOO. With the removal of Articles 340 to 369, this example section is also removed.
Sixth, PMK Number 54 of 2025 removes Article 471 of PMK Number 81 of 2024. This article detailed Appendix EEE, which outlined additional provisions for specific goods, including soybeans, wheat, wheat flour, coal mining commodities, metal minerals, and non-metal minerals, in line with their descriptions and tariff headings under the Harmonized System.
For ease of reference, the table below summarizes the changes:
| No. | PMK Number 54 of 2025 | Substance |
| 1 | Removing Article 1, Numbers 199 to 206 | Definitions related to cryptoassets, electronic means, cryptoasset sellers, etc. |
| 2 | Removing Articles 217 to 225 | Article 22 income tax collection on payments for delivery of goods and activities in import or other business sectors. |
| 3 | Removing Articles 340 to 369 | VAT and income tax on cryptoasset trading transactions. |
| 4 | Removing Article 465, Letter w | Procedures for collecting Article 22 income tax on payments for the delivery of goods and for import/export activities involving coal, metal minerals, and non-metal minerals by license holders, as well as related exemption procedures. |
| 5 | Removing Article 469, Letter l | Regulates the Appendix OOO related to examples of VAT and income tax collection, payment, and reporting on cryptoasset transactions. |
| 6 | Removing Article 471 | Regulates the Appendix EEE related to additional provisions on specific goods, other specific goods, soybeans, wheat, wheat flour, coal mining commodities, metal minerals, and non-metal minerals, in line with their descriptions and tariff headings under the Harmonized System. |
This concludes our summary of the third amendment to PMK Number 81 of 2024. If you need further guidance or information, Ideatax is here to assist.