Minister of Finance Regulation (Peraturan Menteri Keuangan/PMK) Number 59 of 2026 concerning Government-Borne Income Tax on Interest or Returns From Foreign-Currency Government Securities Issued by the Government in the Domestic Primary Market for Fiscal Year 2026.
PMK Number 59 of 2026 provides a government-borne income tax incentive on interest, returns, and discounts from foreign-currency government securities (surat berharga negara/SBN) issued by the government in the domestic primary market. The incentive applies to the June-December 2026 tax periods.
Link to the DHE Policy
The issuance of PMK Number 59 of 2026 is linked to changes in the policy governing export proceeds (devisa hasil ekspor/DHE) from the development, management, and/or processing of natural resources. Government Regulation (Peraturan Pemerintah/PP) Number 36 of 2023, as amended by PP Number 21 of 2026, regulates DHE.
Under the latest amendment, the government added foreign-currency government bonds (surat utang negara/SUN) and/or sharia-compliant bonds (surat berharga syariah negara/SBSN) as instruments for placing DHE. Exporters may therefore place their DHE in foreign-currency SBN. PMK Number 59 of 2026 complements this policy by providing a government-borne income tax incentive on income derived from these instruments.
Structure of the Regulation
PMK Number 59 of 2026 consists of four articles.
- Article 1 defines several terms, including Income Tax Law, SUN, SBSN, tax period, and minister.
- Article 2 sets out the main provisions, including the government-borne income tax incentive, the types of SBN eligible for the incentive, the types of income borne by the government, the definition of issuance in the domestic primary market, and the incentive period.
- Article 3 regulates the implementation and accountability of government-borne income tax subsidy expenditure.
- Article 4 provides that PMK Number 59 of 2026 takes effect from the date of promulgation.
Scope of the Incentive
Article 2(1) provides that income tax payable on interest or returns from foreign-currency SBN issued by the government in the domestic primary market is borne by the government.
The SBN covered by the provision consist of SUN and SBSN. The incentive also covers discounts on foreign-currency SBN arising upon their issuance in the domestic primary market. Accordingly, the income covered by the incentive consists of interest or returns and discounts.
PMK Number 59 of 2026 defines issuance in the domestic primary market as the first-time offering and sale of foreign-currency SBN in Indonesia. In other words, the government-borne income tax incentive applies to initial issuances in the domestic market, rather than transactions involving SBN in the secondary market.
Duration of the Incentive
The government-borne income tax applies to the June-December 2026 tax periods.
This limitation means that the incentive is available only during the period specified in PMK Number 59 of 2026 and does not apply permanently.
Implementation and Accountability
Article 3 provides that the implementation and accountability of government-borne income tax subsidy expenditure must follow the applicable laws and regulations.
PMK Number 92 of 2023 concerning the Mechanism for the Implementation and Accountability of Government-Borne Taxes governs the implementation. Thus, PMK Number 59 of 2026 relies on the existing administrative mechanism for government-borne income tax.
Changes From the Previous Provisions
Before PMK Number 59 of 2026 was issued, interest or returns income from foreign-currency SBN was generally subject to the applicable income tax provisions based on the type of income recipient. No specific government-borne income tax incentive was available for income derived from foreign-currency SBN issued in the domestic primary market.
Meanwhile, before the third amendment to PP Number 36 of 2023, foreign-currency SUN and SBSN were not among the instruments available for DHE placement. PP Number 21 of 2026 added these two instruments as additional options for DHE placement.
PMK Number 59 of 2026 complements this change by providing a government-borne income tax incentive on income derived from foreign-currency SBN issued in the domestic primary market.
Conclusion
PMK Number 59 of 2026 provides a government-borne income tax incentive on interest, returns, and discounts from foreign-currency SBN issued by the government in the domestic primary market. The incentive applies to the June-December 2026 tax periods.
The policy also supports expanding DHE placement instruments by adding foreign-currency SUN and SBSN as DHE placement options under PP Number 21 of 2026.
Taxpayers participating in the primary issuance of foreign-currency SBN in the domestic market during this period should take note of the government-borne income tax incentive and the applicable procedures.
Legal References
- Law of the Republic of Indonesia Number 7 of 1983 concerning Income Tax, as amended by Law of the Republic of Indonesia Number 6 of 2023 concerning the Stipulation of Government Regulation in Lieu of Law of the Republic of Indonesia Number 2 of 2022 concerning Job Creation into Law.
- Law of the Republic of Indonesia Number 24 of 2002 concerning Government Bonds, as amended by Law of the Republic of Indonesia Number 4 of 2026 concerning Amendments to Law of the Republic of Indonesia Number 4 of 2023 concerning the Financial Sector Development and Strengthening.
- Law of the Republic of Indonesia Number 17 of 2003 concerning State Finance.
- Law of the Republic of Indonesia Number 19 of 2008 concerning Sharia-Compliant Bonds.
- Law of the Republic of Indonesia Number 39 of 2008 concerning State Ministries, as amended by Law of the Republic of Indonesia Number 61 of 2024.
- Law of the Republic of Indonesia Number 17 of 2025 concerning the State Budget for Fiscal Year 2026.
- Government Regulation Number 36 of 2023 concerning Export Proceeds From the Development, Management, and/or Processing of Natural Resources, as amended by Government Regulation Number 21 of 2026 concerning the Third Amendment to Government Regulation Number 36 of 2023.
- Presidential Regulation Number 158 of 2024 concerning the Ministry of Finance.
- Presidential Regulation Number 118 of 2025 concerning the Details of the State Budget for Fiscal Year 2026.
- Minister of Finance Regulation Number 92 of 2023 concerning the Mechanism for the Implementation and Accountability of Government-Borne Taxes.
- Minister of Finance Regulation Number 124 of 2024 concerning the Organization and Work Procedures of the Ministry of Finance, as amended by Minister of Finance Regulation Number 117 of 2025.
- Minister of Finance Regulation Number 59 of 2026 concerning Government-Borne Income Tax on Interest or Returns From Foreign-Currency Government Securities Issued by the Government in the Domestic Primary Market for Fiscal Year 2026.
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