Indonesia has issued a crucial regulation governing the implementation of the global minimum tax under the Director General of Taxes Regulation Number 6 of 2026. The regulation lays out the procedures for fulfilling tax rights and obligations under the Global Anti-Base Erosion (GloBE) Rules, part of the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS).
The regulation reflects Indonesia’s push to curb cross-border profit shifting by multinational corporations and strengthen oversight of international tax arrangements. It also provides long-awaited technical guidance for taxpayers ahead of the global minimum tax rollout.
The GloBE Rules introduce a 15% global minimum tax for multinational enterprises (MNEs) that meet certain revenue thresholds. The policy is designed to prevent companies from shifting profits into low-tax jurisdictions and to create a more level international tax environment.
Under PER-6/PJ/2026, Indonesia sets out the administrative framework for implementing the rules, including taxpayer classification, filing requirements, and procedures for top-up tax payments.
Core Concepts Under the GloBE Rules
This regulation introduces several core concepts that form the basis of the global minimum tax regime in Indonesia, including:
- MNE groups;
- constituent entities;
- ultimate parent entities;
- effective tax rates;
- covered taxes; and
- substance-based income exclusion (SBIE).
The regulation also outlines the following three primary schemes within the GloBE framework.
Income Inclusion Rule (IIR)
The IIR allows a parent entity to be subject to top-up tax when subsidiaries within the group are taxed below the 15% minimum effective tax rate.
Undertaxed Payments Rule (UTPR)
The UTPR acts as a backstop mechanism when the IIR is not applied or does not fully capture the top-up tax obligation.
Domestic Minimum Top-Up Tax (DMTT)
The DMTT gives source countries, including Indonesia, the first right to impose a domestic top-up tax on entities with an effective tax rate below the global minimum threshold.
Scope of the Regulation
PER-6/PJ/2026 extends well beyond reporting obligations. The regulation also governs taxpayer registration, top-up tax payments, compliance monitoring, audits, and dispute-resolution procedures under the GloBE Rules.
Accordingly, the regulation serves as the primary operational framework for both taxpayers and the Directorate General of Taxes (DGT) in implementing the global minimum tax in Indonesia.
One of the regulation’s important provisions concerns the criteria for GloBE taxpayers. A constituent entity or joint venture within an MNE group will fall under the regime if the group records consolidated annual gross revenue of at least EUR 750 million.
The threshold must be met in at least two of the four fiscal years preceding the relevant GloBE fiscal year.
Registration and Revocation of GloBE Taxpayer Status
PER-6/PJ/2026 also requires taxpayers meeting the requirements to apply electronically for GloBE taxpayer status through the taxpayer portal no later than nine months after the end of the group’s first GloBE fiscal year.
If no application is submitted, the DGT may designate the taxpayer ex officio based on administrative review.
Additionally, the regulation also governs amendments to taxpayer data and status revocation, including changes relating to:
- taxpayer identity;
- ultimate parent entity;
- MNE group structure;
- correspondence address; and
- administrative contacts.
The tax authority may revoke GloBE taxpayer status if the MNE group no longer satisfies the revenue threshold or if the taxpayer deletes their identification number (nomor pokok wajib pajak/NPWP).
Filing Obligations Under the GloBE Regime
From a compliance perspective, taxpayers subject to the GloBE regime are required to file tax returns, including:
- GloBE income tax returns;
- UTPR income tax returns; and
- DMTT income tax returns.
Each return serves a distinct purpose depending on the taxpayer’s position within the MNE group structure.
The filings themselves are highly technical, covering top-up tax calculations under the IIR, UTPR, and DMTT schemes across jurisdictions. Supporting schedules must also include:
- GloBE profit or loss calculations;
- adjusted covered taxes;
- exclusions for international shipping income;
- SBIE calculations; and
- additional current top-up tax calculations.
Taxpayers must file all submissions electronically through the taxpayer portal.
GloBE Return Filing Deadlines
Generally, taxpayers must submit tax returns under the GloBE regime within four months of the end of the GloBE fiscal year.
For the first year of implementation, taxpayers may request an additional two-month extension by filing a notification with the tax authority. The provision implies the government’s recognition of the complexity involved in calculating global minimum tax obligations during the initial implementation stage.
GloBE Information Return (GIR)
In addition to tax returns, taxpayers may also be required to submit a GIR. The GIR must be filed by the ultimate parent entity or designated filing constituent entity in XML format consistent with OECD standards. The document includes:
- details of constituent entities;
- group ownership structures;
- effective tax rate calculations by jurisdiction;
- top-up tax allocations; and
- elections made under the GloBE Rules.
The GIR must be submitted within 15 months after the end of the fiscal year, or within 18 months for the first year of implementation.
Taxpayers may amend the GIR if errors are identified. The regulation also outlines notification obligations for taxpayers that do not submit the GIR directly.
Digital Administration Through Coretax
The DGT will process filings through the Coretax system, which automatically validates NPWP and performs formal checks on filing completeness.
If all requirements are satisfied, the system will issue an electronic receipt. The digitization of the process forms part of Indonesia’s broader effort to modernize tax administration.
Top-Up Tax Payment Procedures
PER-6/PJ/2026 also establishes procedures for paying top-up taxes under the IIR, UTPR, and DMTT schemes.
Payments must be made by the end of the GloBE fiscal year using tax account code “411618,” along with the appropriate payment type codes for the applicable top-up tax category. By this means, taxpayers receive improved administrative certainty and compliance monitoring of global minimum tax payments.
The regulation also addresses post-filing adjustments. If changes in covered taxes reduce the effective tax rate, taxpayers must recalculate the top-up tax through an additional current top-up tax mechanism.
For relatively small adjustments below an aggregate threshold of EUR 1 million per jurisdiction, however, taxpayers may apply simplified administrative treatment.
DGT Oversight and Audit Powers
From an enforcement standpoint, the DGT has broad authority to supervise compliance under the GloBE regime. The tax authority may:
- request explanations and supporting data;
- hold discussions with taxpayers;
- request transfer pricing documentation;
- review consolidated financial statements; and
- conduct site visits.
At the same time, taxpayers retain the right to file corrections, objections, appeals, or legal claims under prevailing tax dispute procedures.
With the implementation of PER-6/PJ/2026, Indonesia moves further into a new phase of international tax governance, shaped by transparency, coordination, and global minimum tax standards.
Navigating Indonesia’s new global minimum tax rules requires careful planning. If you need strategic advice or compliance assistance, Ideatax is here to guide your business.
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