The Directorate General of Taxes (DGT) has issued Director General of Taxes Regulation Number PER-12/PJ/2026 on Amendments to Regulation of the Director General of Taxes Number PER-11/PJ/2025 on Provisions for Reporting Income Tax, Value Added Tax (VAT), Luxury-Goods Sales Tax (LGST), and Stamp Duty under the Core Tax Administration System.
PER-12/PJ/2026 was stipulated on September 28, 2026, by Director General of Taxes Bimo Wijayanto and took effect on October 1, 2026. The main change introduced by the regulation concerns the mechanism for amending tax returns. While amendments previously used a difference or delta approach, the calculation now also takes into account payments and refunds that have already been made.
Scope of Changes
The considerations section of PER-12/PJ/2026 sets out three considerations. First, the government needs to provide greater ease and legal certainty in fulfilling tax obligations through a more effective tax administration system, including the issuance of income tax withholding and/or collection certificates and equivalent documents.
Second, PER-11/PJ/2025 does not yet accommodate these needs and therefore needs to be amended. Third, based on these considerations, an amendment to PER-11/PJ/2025 needs to be issued.
In terms of its legal basis, PER-12/PJ/2026 refers, among other regulations, to the General Provisions and Tax Procedures Law, the Income Tax Law, and the Value Added Tax (VAT) Law, as amended several times.
PER-12/PJ/2026 consists of two articles. Article I contains 15 amendments to PER-11/PJ/2025, while Article II governs transitional provisions and the effective date of the regulation.
The amendments cover general provisions, withholding certificates, monthly Article 21/26 Income Tax returns, Unified Income Tax, VAT, LGST, annual Income Tax returns, tax credits, and follow-up procedures for tax refund applications.
Under the general provisions, seven definitions, namely numbers 11, 18, 77, 78, 80, 81, and 82, have been removed. Four new definitions have also been added, namely Tax Assessment Letter, Tax Assessment Letter of Overpayment, Preliminary Tax Overpayment Refund Decision, and Article 29 Income Tax.
Withholding Certificates and Tax Return Reporting
Articles 6 and 17 stipulate that electronic signatures on Article 21/26 Income Tax withholding certificates and Unified Income Tax withholding and/or collection certificates are made by the withholding or collecting agent.
Withholding or collecting agents may appoint one or more officials or employees to sign the certificates through the Taxpayer Portal.
Article 7 governs the preparation of BPA1, BPA2, BP21, and BP26 forms. BP21 and BP26 may be prepared for each transaction or for one Tax Period, in accordance with applicable provisions.
Article 19 also redefines documents treated as equivalent to Standard-Format Unified Income Tax Withholding and/or Collection Certificates.
Meanwhile, Article 11 adds data that must be included in monthly Article 21/26 Income Tax returns, including the amount of tax underpaid or overpaid as a result of an amendment.
Changes to Tax Return Amendment Mechanism
Previously, tax return amendments in Coretax used a delta approach. The calculation was essentially based on the difference between the tax return position before and after the amendment.
This approach could result in an underpayment position even when a taxpayer had already made a payment or received a refund for the same Tax Period.
PER-12/PJ/2026 changes this mechanism. Amendments now take into account payments and refunds made or issued before the amended tax return is submitted.
VAT and LGST
Article 29B stipulates that an underpayment, overpayment, or nil VAT position resulting from an amendment must take into account all underpayment settlements and all refunds of overpayments that have been issued for the amended Tax Period before the amendment is submitted.
Refunds taken into account include Preliminary Tax Overpayment Refund Decisions under Articles 17C and 17D of the KUP Law, as well as Tax Assessment Letters of Overpayment issued for applications to refund tax that was not actually due.
Accordingly, the amended tax return calculation no longer compares only the original and amended returns, but also takes into account payments and refunds that have already occurred. The same mechanism applies to LGST.
Article 21/26 Income Tax
For Article 21/26 Income Tax, Article 12 paragraph (2a) takes into account all Article 21/26 Income Tax payments made before the amendment. Articles 13A and 13B govern adjustments to tax credit balances.
For example, a withholding agent pays IDR 100 million for the May Tax Period, while the actual Article 21/26 Income Tax liability is IDR 90 million. This results in an overpayment of IDR 10 million, which is credited against the June Tax Period.
Following an amendment, the actual tax liability for May is found to be IDR 95 million. This results in an overpayment of IDR 5 million. The tax credit balance is adjusted downward by IDR 5 million and taken into account in the first normal monthly Article 21/26 Income Tax return submitted after the amended Tax Period.
Unified Income Tax
Article 25 paragraphs (1a) to (1c) stipulate that amendments to Unified Income Tax returns must take into account all Income Tax amounts stated in Unified Income Tax withholding and/or collection certificates that have been paid, as well as all refunds of overpaid tax that was not actually due through a Tax Assessment Letter of Overpayment.
If the amended return results in an underpayment, the shortfall must be paid into the state treasury. If it results in an overpayment, the excess may be claimed for a refund in accordance with applicable laws and regulations.
Annual Income Tax Returns
Article 80A stipulates that amendments to annual Income Tax returns must take into account Article 29 Income Tax payments and preliminary refunds that have already been issued.
Examples of Tax Return Amendments
VAT Preliminary Refund
A taxable entrepreneur (PKP) reports a monthly VAT return for the October 2027 Tax Period showing an overpayment of IDR 600 million and receives a Preliminary Tax Overpayment Refund Decision for IDR 600 million.
Following an amendment, the actual overpayment is only IDR 500 million. Under Article 29B, the amount is offset against the IDR 600 million refund already received. As a result, an underpayment of IDR 100 million arises and must be paid into the state treasury.
VAT Tax Credit
The March monthly VAT return reports an overpayment of IDR 500 million and carries it forward to the following Tax Period. Following an amendment, the March overpayment is reduced to IDR 400 million.
If the April and May returns have already been filed while the June return has not yet been filed, the tax credit balance is adjusted downward by IDR 100 million. The adjustment is taken into account in the first normal monthly VAT return that has not yet been filed after the amended Tax Period, namely the June return.
Article 21/26 Income Tax Tax Credit
A withholding agent pays IDR 100 million for the May Tax Period, while the actual Article 21/26 Income Tax liability is IDR 90 million. The IDR 10 million overpayment is credited against the June Tax Period.
Following an amendment, the actual Article 21/26 Income Tax liability for May is IDR 95 million. Accordingly, the actual overpayment is only IDR 5 million. The tax credit balance is adjusted downward by IDR 5 million and taken into account in the first normal monthly Article 21/26 Income Tax return submitted after the amended Tax Period.
Tax Return Amendment and Tax Credit Provisions
In principle, a tax return may only be amended as long as the DGT has not commenced an audit or an open preliminary evidence examination of the relevant tax return.
Article 29A also stipulates that a monthly VAT return for a Tax Period must be filed after the monthly VAT return for the preceding Tax Period has been filed. An exception applies if an audit or an open preliminary evidence examination is being conducted for the preceding Tax Period.
Article 29E governs adjustments to tax credits arising from monthly VAT returns for December 2024 and earlier Tax Periods that showed overpayments and were carried forward to January 2025. It also sets out the mechanism for filing amended returns and supporting documents.
Articles 129A and 129B govern the consequences of tax return amendments. Tax rights and obligations are determined based on the latest amended tax return submitted.
A refund application based on an overpaid tax return that is subsequently amended will not be processed under certain circumstances, including where a decision has not yet been issued or an audit has not yet commenced, depending on the applicable refund process.
Taxpayers will receive notification when an application is not processed as part of the review of a refund of tax that was not actually due or a preliminary tax overpayment refund.
In addition, if an annual Income Tax return has already received a decision approving an installment arrangement or deferral of Article 29 Income Tax payment, the decision will cease to apply once an amended annual Income Tax return is submitted.
Transitional Provisions
Article II governs the treatment of tax returns submitted before PER-12/PJ/2026 took effect.
Tax returns filed and/or amended before October 1, 2026, for which processing or follow-up action has not yet been completed, will continue to be handled under PER-11/PJ/2025.
Meanwhile, amendments submitted after PER-12/PJ/2026 takes effect will be subject to the new provisions for Tax Periods beginning January 2025, portions of Tax Years ending from January 2025 onward, or Tax Years beginning in 2025. The provisions also apply to tax returns submitted before PER-12/PJ/2026 took effect.
Accordingly, taxpayers need to consider two factors in determining which provisions apply: the date the amendment is submitted and the tax period covered by the amendment.
Key Points for Taxpayers
Before filing an amended tax return, taxpayers should reconcile all payments, refunds, and tax credit balances related to the amended Tax Period or Tax Year.
An underpayment, overpayment, or nil position in an amended tax return is no longer determined solely by the difference between the original and amended returns. Payments and refunds that have already occurred must also be taken into account, depending on the type of tax involved.
Taxpayers should also review the history of overpayment tax credits, as adjustments to tax credit balances may affect subsequent monthly tax returns.
For Coretax users, a tax return amendment should be viewed as part of the broader tax administration process for the same Tax Period or Tax Year. Accordingly, taxpayers should reconcile their tax returns, payments, refunds, and tax credit balances before submitting an amendment.
Legal References
- Law of the Republic of Indonesia Number 6 of 1983 concerning General Tax Provisions and Procedures, as amended several times, most recently by Law of the Republic of Indonesia Number 7 of 2021.
- Law of the Republic of Indonesia Number 7 of 1983 concerning Income Tax, as amended several times, most recently by Law of the Republic of Indonesia Number 7 of 2021.
- Law of the Republic of Indonesia Number 8 of 1983 concerning Value Added Tax on Goods and Services and Luxury Goods Sales Tax, as amended several times, most recently by Law of the Republic of Indonesia Number 7 of 2021.
- Government Regulation Number 58 of 2023 concerning Income Tax Article 21 Withholding Rates on Income Related to Employment, Services, or Activities of Individual Taxpayers.
- Minister of Finance Regulation Number 81 of 2024 concerning Tax Provisions in the Context of the Implementation of the Core Tax Administration System, as amended several times, most recently by Minister of Finance Regulation Number 1 of 2026.
- Regulation of the Director General of Taxes Number PER-11/PJ/2025 concerning Provisions for Reporting Income Tax, Value Added Tax, Luxury Goods Sales Tax, and Stamp Duty in the Context of the Implementation of the Core Tax Administration System.
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