On May 4, 2026, the Director General of Taxes issued Director General of Taxes Regulation Number PER-6/PJ/2026 concerning Procedures for Exercising Global Minimum Tax Rights and Obligations Under International Agreements. The regulation implements Article 65(15) of Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 136 of 2024, which governs the global minimum tax (GMT). While PMK Number 136 of 2024 establishes the substantive elements, PER-6/PJ/2026 provides the detailed administrative procedures taxpayers must comply with.
Understanding the GloBE Rules
The Global Anti-Base Erosion (GloBE) Rules are part of the international tax reform developed by the OECD and G20 through the Inclusive Framework on Base Erosion and Profit Shifting. The rules aim to ensure that large multinational enterprise groups pay an effective tax rate of at least 15% in every jurisdiction where they operate. Where the effective tax rate falls below that threshold, a top-up tax applies to bring the effective rate up to the minimum level. Indonesia adopted these rules through PMK Number 136 of 2024, while PER-6/PJ/2026 governs their practical implementation.
Taxpayers Subject to the GloBE Rules
The GloBE Rules apply only to constituent entities or joint venture group members of multinational enterprise groups with consolidated gross turnover of at least EUR 750 million in at least two of the four fiscal years preceding the applicable GloBE year. The rules therefore only target large-scale multinational enterprises.
Eligible taxpayers must register for GloBE taxpayer status through the taxpayer portal no later than nine months after the end of their first GloBE fiscal year. If a taxpayer fails to register, the Directorate General of Taxes (DGT) may assign GloBE status ex officio based on available administrative data. Taxpayers are also required to report any changes to their corporate identity, ultimate parent entity, group information, correspondence address, or administrative contact details. Conversely, GloBE taxpayer status may be revoked if the group no longer satisfies the gross turnover threshold.
Three Top-Up Tax Mechanisms
PER-6/PJ/2026 outlines three mechanisms for imposing top-up tax. First, the income inclusion rule (IIR) applies when an Indonesian parent entity must pay top-up tax because another group entity is subject to an effective tax rate below 15% in another jurisdiction. Second, the under-taxed payments rule (UTPR) serves as a backstop where the full top-up tax has not been collected under the IIR, allowing part of the tax liability to be allocated to entities in Indonesia. Domestic minimum top-up tax (DMTT) allows top-up tax to be imposed on Indonesian constituent entities with an effective tax rate under 15%. Indonesia collects the top-up tax before another jurisdiction applies the IIR or UTPR.
GloBE Annual Tax Return
GloBE taxpayers must file a dedicated GloBE annual tax return, separate from the regular corporate income tax return. The return consists of a main form and three appendices. The main tax return form includes the GloBE return for the ultimate parent entity, the UTPR return, where top-up tax allocations are available, and the DMTT return, which all GloBE taxpayers must complete.
The appendices contain detailed calculations of top-up tax under the IIR, UTPR, and DMTT mechanisms, including GloBE income or loss, adjusted covered taxes, excluded income, the substance-based income exclusion (SBIE), and other required calculation components. All filings must be submitted electronically through the taxpayer portal using an electronic signature, in Indonesian language, with Latin characters and Arabic numerals.
The tax return must generally be filed within four months after the end of the relevant GloBE fiscal year. For the first reporting year, taxpayers may request an extension of up to two months, provided they submit the request before the filing deadline and pay any outstanding tax.
GIR dan Notification Requirements
In addition to the tax return, ultimate parent entities that qualify as GloBE taxpayers must submit a GloBE information return (GIR). The GIR includes information on all constituent entities within the group, ownership structure, effective tax rate calculations for each jurisdiction, top-up tax allocations under the IIR and UTPR, and other information required under the GloBE Rules. The return must be filed electronically in XML format through the taxpayer portal.
Where the ultimate parent entity is located outside Indonesia, a designated Indonesian GloBE taxpayer or another reporting entity in accordance with the regulation may submit the GIR. They must submit the GIR within 15 months after the end of the GloBE fiscal year, or 18 months for the first reporting year.
Each GloBE taxpayer must also submit a notification identifying the ultimate parent entity, the constituent entity in Indonesia, and the designated GIR filing entity. If a taxpayer belongs to more than one group, a separate notification must be submitted for each group. The notification is not required if the taxpayer has already submitted the GIR, as the necessary information is included in the form. The filing deadline mirrors that of the GIR, 15 months, or 18 months for the first reporting year.
Top-Up Tax Payment
Any top-up tax arising under the IIR, UTPR, or DMTT must be paid by the end of the relevant GloBE fiscal year. Payments are made using tax account code 411618, with payment type code 610 for IIR, 620 for UTPR, and 630 for DMTT. These codes enable the tax administration to distinguish among the different types of top-up tax payments.
Post-Filing Adjustments
PER-6/PJ/2026 also guides adjustments to covered taxes made after the tax return has been filed. Rather than requiring taxpayers to amend prior-year returns, post-filing adjustments are recognized in the GloBE fiscal year in which the adjustment occurs.
If the adjustment increases covered taxes, the increase is recognized in the current year. Conversely, if covered taxes decrease, taxpayers must recalculate the effective tax rate and top-up tax using the mechanism. The recalculation is based on the adjusted covered taxes and GloBE profits for the year in which the reduction occurs.
An exception applies for immaterial reductions. If the aggregate reduction in covered taxes is less than EUR 1 million per jurisdiction in a given year, taxpayers may recognize the adjustment in the current year without recalculating the effective tax rate. If the reduction reaches or exceeds that threshold, the additional current top-up tax continues to apply.
Outside these specific adjustment rules, taxpayers may still voluntarily amend their tax returns to correct filing errors that do not fall within this special adjustment mechanism.
Tax Monitoring and Audits
The DGT is authorized to monitor compliance by both registered GloBE taxpayers and entities that should have registered but have not yet done so. Monitoring covers compliance with tax return filings, top-up tax payments, GIR submissions, notifications, and other tax obligations.
As part of its oversight, the DGT may request explanations, invite taxpayers to in-person or virtual discussions, conduct site visits, issue nudge letters or warning letters, and request supporting documentation such as consolidated financial statements, transfer pricing documentation, and other records used to calculate top-up tax.
The DGT may also conduct tax audits to verify compliance with the GloBE Rules or for other purposes under general tax legislation.
Legal Remedies
GloBE taxpayers are entitled to the same legal remedies available to other taxpayers, including the right to request corrections, file objections, apply for reductions, cancellations, or annulments of tax decisions. The Director General of Taxes may also correct tax assessments containing clerical errors, calculation mistakes, or incorrect applications of tax regulations.
Taxpayers may file objections against tax underpayment assessment letters, additional tax underpayment assessment letters, nil tax assessment letters, and tax overpayment assessment letters. Taxpayers may file an appeal to the Tax Court if the objection is rejected or they remain dissatisfied with the decision. Lawsuits relating to tax collection procedures or other tax decisions may also be filed with the Tax Court under the applicable legal provisions.
Transitional and Administrative Provisions
PER-6/PJ/2026 allows GloBE tax returns to be prepared either in rupiah or in the currency used in the group’s consolidated financial statements. Where entities within the same group use different reporting currencies, the group must select a single reporting currency that will remain in use for five years for top-up tax calculations.
The GloBE fiscal year follows the taxpayer’s accounting period. However, where this differs from the accounting period of the ultimate parent entity located outside Indonesia, reporting must follow the ultimate parent entity’s GloBE fiscal year to ensure consistency across the group.
The regulation also introduces a simplified jurisdictional reporting framework as a transitional measure. Under this framework, reporting constituent entities may submit a simplified GIR for jurisdictions where no top-up tax liability exists or where detailed entity-level allocation is unnecessary. In such cases, income or loss adjustments may be reported on an aggregated jurisdictional basis. The transitional relief applies to GloBE fiscal years beginning on or before December 31, 2028, and ending before June 30, 2030. Nevertheless, the DGT may request more detailed information where necessary.
The regulation further allows GIR submitted to the DGT to be exchanged automatically with partner jurisdictions under applicable competent authority agreements.
Conclusion
PER-6/PJ/2026 establishes the implementing procedures for Indonesia’s GMT regime, covering top-up tax payments, post-filing adjustments, compliance monitoring, audits, legal remedies, transitional provisions, and information exchanges. For multinational enterprise groups within the scope of the GloBE Rules, understanding these requirements is paramount to ensuring compliance with prevailing tax regulations.
Legal Basis
- Minister of Finance Regulation Number 136 of 2024 concerning the Implementation of the Global Minimum Tax Under International Agreements.
- Director General of Taxes Regulation Number PER-6/PJ/2026 concerning Procedures for Exercising Global Minimum Tax Rights and Obligations Under International Agreements.
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