The property sector is a major contributor to Indonesia’s economy. Including its supply chain, the sector contributes about 14% of Indonesia’s gross domestic product (GDP). Macroeconomic conditions, particularly inflation and Bank Indonesia’s benchmark interest rate, affect consumer purchasing power and developers’ access to construction financing.
An Economic Growth Driver
According to Statistics Indonesia (Badan Pusat Statistik/BPS), Indonesia’s economy has continued to grow by more than 5% despite ongoing global economic uncertainty. This growth has helped sustain consumer purchasing power, including among middle-income consumers, who represent one of the property sector’s main market segments.
In 2025, Indonesia’s economy grew by 5.11% cumulatively (c-to-c), while the real estate sector also recorded positive growth.
| Economic Indicator | Contribution / Performance | Characteristics & Economic Impact |
| Construction Share of GDP | 9.79% | Construction remains the fourth-largest contributor to Indonesia’s GDP structure. |
| Real Estate Share of GDP | 2.17% | Represents the economic value generated by the provision, transaction, and management of commercial/residential property rental. |
| Sector Growth (Q2-2026) | Construction: +6.68% Real Estate: +3.64% | Construction recorded strong growth acceleration, while real estate maintained steady growth amid adjustments in the benchmark interest rate. |
| Combined Property Ecosystem Contribution | 14.6% – 16.3% | Represents the aggregate upstream and downstream economic output generated by building construction, real estate activities, and industrial material supply chains. |
| Employment | ~13.8 million people | A labor-intensive sector that employs about 9.61% of Indonesia’s total working population. |
| Multiplier Effect | Supports 185 subsectors | Stimulates domestic industrial supply chains with limited reliance on imports, spanning cement, steel, paint, furniture, and mortgage banking services. |
| Contribution to Locally-Generated Revenue (LGR) | 31.9% (one-third of LGR) | Provides a highly stable source of local government revenue through regional taxes, land and building acquisition duty (bea perolehan hak atas tanah dan bangunan/BPHTB) on transactions, and annual rural and urban land and building tax (pajak bumi dan bangunan pedesaan dan perkotaan/PBB-P2). |
Source: BPS and Coordinating Ministry of Economic Affairs, compiled.
In the first quarter of 2026, Indonesia’s economy contracted by 0.77% quarter-on-quarter (QoQ), before rebounding by 3.73% in the second quarter of 2026. During the second quarter of 2026, the real estate sector grew by 3.64% and accounted for 2.17% of GDP.
Cumulatively, in the first half of 2026, government consumption grew by 18.62%, while gross fixed capital formation (GFCF) increased by 6.87%. The expansion in GFCF points to stronger physical investment activity, including in the construction and property sectors.
Supporting 185 Industry Subsectors
The property sector’s economic impact extends beyond residential property sales through its linkages with a wide range of industries. According to the Coordinating Ministry of Economic Affairs, the property industry is connected to at least 185 other industry subsectors.
The property sector supply chain can be divided into three segments. First, upstream industries covering materials and construction. This segment includes cement, steel, ceramics, paint, glass, and wood-based products. In the first half of 2026, the manufacturing sector grew by 4.78%, supported by domestic demand, including from construction activity.
Second, financial services covering banking and financing. Banks play an important role in providing mortgages to homebuyers and construction loans to developers. Property sales performance influences credit demand, while the non-performing loan (NPL) ratio for construction lending indicates the sector's financing quality.
Third, downstream industries and supporting services. This segment includes architectural and civil engineering, notaries/land deed officials, property marketing agents, furniture and household goods, logistics, and transportation. The development of transit-oriented developments (TODs) also increases demand for utilities such as electricity, water, and gas.
Indonesia’s Property Market Structure
The property market structure varies by segment. Township developments tend to be concentrated among a relatively small number of major developers, while the subsidized housing segment is more fragmented and comprises numerous smaller developers.
Listed companies dominate the national property market, with substantial market capitalization and extensive land banks. Based on Indonesia Stock Exchange (IDX) market capitalization data, the five largest listed property companies are as follows:
| Rank | Company | Ticker | Market Capitalization (As of June 2026) | Main Project Focus |
| 1 | PT Pantai Indah Kapuk Dua Tbk | PANI | IDR 105.00 Trillion | Large-scale integrated coastal township development in Pantai Indah Kapuk 2 (PIK 2). |
| 2 | PT Maha Properti Indonesia Tbk | MPRO | IDR 86.50 Trillion | Integrated residential developments, office buildings, and mixed-use development. |
| 3 | PT Metropolitan Kentjana Tbk | MKPI | IDR 19.41 Trillion | Premium recurring-income property portfolio in South Jakarta, including Pondok Indah Mall. |
| 4 | PT Bangun Kosambi Sukses Tbk | CBDK | IDR 18.90 Trillion | Exclusive development of the Central Business District (CBD) and commercial infrastructure within PIK 2. |
| 5 | PT Jaya Real Property Tbk | JRPT | IDR 13.94 Trillion | Mass-transit-oriented township development in Bintaro Jaya and surrounding areas. |
Large developers benefit from several advantages, including strong cash positions and diversified revenue streams. Recurring income from commercial assets can reduce their reliance on primary property sales and help sustain performance during market slowdowns.
Several factors contribute to the property industry’s relatively high barriers to entry. First, substantial capital requirements. Land acquisition requires significant upfront equity. New developers have more limited access to financing than listed companies, which can issue bonds or rights issues.
Second, complex licensing requirements. Uncertainty surrounding detailed spatial plans (rencana detail tata ruang/RDTR) and the process of obtaining building approvals (persetujuan bangunan gedung/PBG) can delay project implementation and increase pre-operating costs.
Third, the fiscal burden before sales are generated. Before projects begin generating positive cash flow, developers may already face final income tax obligations and value-added tax (VAT) on construction materials. Input VAT that cannot be promptly credited or refunded can further pressure cash flow.
Fourth, confidence among banks and consumers. Banks tend to be more selective when extending construction financing to new developers. Homebuyers also consider a developer’s track record when deciding whether to purchase a property.
Despite these barriers, the property market still has considerable room for growth, particularly given the substantial housing needs. Data from the Ministry of Housing and Settlement Areas and BPS in 2025 indicate a housing backlog, which is the gap between housing needs and the availability of decent housing, of approximately 15 million units, up from 9.9 million units based on the 2023 National Socio-Economic Survey. In addition, approximately 26 million homes are classified as inadequate and require improvement or replacement.
Opportunities for new developers may be greater in segments where they do not compete directly with major developers in premium locations. Developers can participate in the government’s three million homes program for low-income households (masyarakat berpenghasilan rendah/MBR) by utilizing the housing financing liquidity facility, which provides access to lower-interest mortgage financing. This segment combines significant housing demand with government-backed financing support.
Furthermore, developers can pursue smaller-scale vertical housing projects near mass-transit hubs through infill development and micro-TOD models, particularly in satellite cities. This approach allows productive use of underutilized land while targeting consumers who prioritize access to public transportation.
Property Sector Structural Challenges
The property sector's challenges cannot be addressed solely through short-term incentives such as government-borne VAT. Several fundamental issues require structural policy responses.
1. Multiple Layers of Taxation
The property industry faces multiple taxes and levies, including VAT of 11% to 12%, BPHTB of up to 5%, final income tax of 2.5%, PBG levies, and other regional charges. Combined, these costs can bring total transaction costs to approximately 18% to 20% of an asset’s value, which reduces investment efficiency.
The government needs to prepare a more coordinated fiscal framework for the property sector, involving both the central and regional governments. One possible measure would be to promote nationally standardized BPHTB incentives for first-time homebuyers.
To offset potential reductions in LGR, the central government could provide additional general allocation funds (dana alokasi umum/DAU) or revenue sharing funds (dana bagi hasil/DBH) incentives to regional governments that successfully increase housing development and homeownership among MBR.
2. Spatial Planning and Licensing Uncertainty
Large-scale developers acquire land with investment horizons of 5–15 years. Changes in regional regulations, overlapping forestry maps, and revisions to RDTR can alter land-use designations and affect investment value.
The government needs to strengthen the integration and reliability of spatial planning data. The Ministry of Agrarian Affairs and Spatial Planning/National Land Agency should also provide legal certainty for issued permits.
Where a developer has obtained the necessary permits and land-use approvals before an RDTR revision, subsequent spatial planning changes should include clear transitional provisions to protect lawfully acquired rights.
The digitalization of online single submission (OSS) services, environmental approvals, and PBG should also be supported by clear service-level agreements (SLAs). Regional governments must have oversight and accountability mechanisms for licensing processes that exceed prescribed time limits.
3. Limited Housing Finance for MBR
The MBR segment faces financing constraints, particularly because it relies on the state budget and limited financing quotas. As of July 2026, approximately 102,900 units had received financing under the housing financing liquidity facility (fasilitas likuiditas pembiayaan perumahan/FLPP) scheme against a proposed quota of 350,000 units for 2026.
This presents a challenge to achieving the government’s target of building up to three million homes annually. The government needs to diversify housing finance sources and reduce reliance on the state budget. The Public Housing Savings Management Agency should be optimized as a source of long-term housing finance.
Bank Indonesia could also strengthen macroprudential incentives for banks that increase lending to MBR. One option would be to provide proportional relief from statutory reserves requirement based on the amount of housing credit for MBR.
In addition, the government needs to improve the secondary mortgage market to enable banks to securitize their low-income mortgage portfolios. This approach could enhance banking-sector liquidity and expand banks’ capacity to provide housing finance.
4. Tax Risk Associated With Related-Party Loans
Property development requires substantial upfront capital expenditure. Land acquisition, site preparation, infrastructure development, and construction all require cash outflows before developers begin generating sales revenue. Meanwhile, the release of funds received from customers through pre-sales is subject to requirements relating to construction progress.
These circumstances make developers, particularly those using special purpose vehicles (SPVs) for specific projects, dependent on debt financing. In addition to bank loans, SPVs may obtain funding through shareholder loans or financing from their holding companies to meet their cash requirements.
Bank financing offers an advantage from a withholding tax perspective, as interest payments to banks are not subject to Article 23 income tax. However, construction loans generally carry high interest rates, require collateral, and offer less flexibility in disbursement timing. Related-party financing therefore provides an alternative funding source for property SPVs.
Tax risks arise when an SPV pays interest to a related party. If the lender is a domestic company, the SPV must withhold Article 23 income tax at 15% of the gross interest payment. If the lender is based overseas, the interest payment is subject to Article 26 income tax at 20%, or the applicable treaty rate, provided the relevant tax residency documentation requirements are satisfied.
To avoid additional cash outflows arising from interest payments and withholding taxes, corporate groups may structure their financing as interest-free loans. However, the Directorate General of Taxes (DGT) may still scrutinize interest-free financing between related parties under the arm’s length principle.
Cancelling the interest-free treatment may raise another issue. If the DGT deems interest on the loan and imposes Article 23 income tax, the deemed interest may also be challenged for corporate income tax purposes.
Property companies generally operate with high levels of debt. Where the debt-to-equity ratio exceeds the prescribed limit, interest expense may become non-deductible in calculating taxable income. This condition can create a further issue where the DGT simultaneously uses the same interest as the basis for imposing Article 23 income tax.
Tax Policy Framework
Tax policy is one instrument available to the government to influence both demand and supply in the property market. However, each measure's effectiveness depends on how it is designed and implemented.
1. Government-Borne VAT Incentive
To maintain purchasing power and stimulate the housing market, the government has extended the government-borne value-added tax (PPN DTP) incentive through Finance Minister Regulation (PMK) No. 90 of 2025 for the 2026 fiscal year.
According to the Directorate General of Taxes (DGT) 2025 Audited Financial Report, the budget allocated for the PPN DTP incentive for the housing sector stood at IDR 4.42 trillion. Realization reached IDR 3.80 trillion, leaving around IDR 618.3 billion in unspent funds. This brought the budget absorption rate to 86.02%.
For 2026, the Ministry of Finance has allocated IDR 3.4 trillion for the PPN DTP program for commercial housing. The budget is expected to support the purchase of around 40,000 commercial housing units, including landed houses and apartment units. The target is higher than the previous year's projection of around 30,000 units.
However, the implementation of the incentive still faces a number of administrative and technical challenges. In addition to market conditions in certain subsectors, such as apartments in Greater Jakarta (Jabodetabek), the challenges also stem from administrative requirements and tax validation processes.
Under PMK No. 90/2025, the government covers 100% of the VAT payable on the portion of the tax base (DPP) of up to IDR 2 billion. The facility is intended for end consumers and is subject to several requirements. The PPN DTP applies only to landed houses or apartment units with a maximum selling price of IDR 5 billion. Transactions exceeding this threshold are not eligible for the incentive.
Eligible properties must be new and ready for occupancy, handed over for the first time by the seller or developer, which must be a taxable entrepreneur (PKP), and must not have been previously transferred to another party.
In terms of beneficiaries, the PPN DTP facility is granted based on a population identification number (NIK) or taxpayer identification number (NPWP). Each individual may use the facility for only one property unit. Married couples may use the facility separately, one unit each, provided they use different NIKs and meet all applicable requirements.
Eligibility for the PPN DTP does not end with the payment of a down payment. The transaction must be evidenced by a sale and purchase deed (AJB) or a fully paid sale and purchase agreement (PPJB) executed before a notary. The buyer must also take physical possession of the property, as evidenced by a handover report (BAST). For the 2026 fiscal year, the BAST must be signed between January 1 and December 31, 2026.
After the BAST is issued, the developer, as a PKP, must issue a tax invoice in accordance with applicable regulations. The use of the Core Tax Administration System (Coretax) also requires developers to use the appropriate transaction code and facility information.
One of the challenges in implementing the PPN DTP is the validation process after the unit has been handed over. Each house or apartment unit handed over to a buyer must have a house identification code (KIR). The code is obtained through the Developer Information System (Sikumbang) application.
The BAST signed by the buyer must be uploaded by the developer to Sikumbang no later than the end of the month following the month in which the handover takes place. The document must contain information such as the seller's name and NPWP, the buyer's NPWP or NIK, the handover date, and a stamped statement.
In practice, the process may be disrupted by delays in uploading documents, system outages, or discrepancies in the buyer's identification data. If the BAST is not validated or registered in accordance with the applicable requirements, the head of the relevant Tax Office (KPP) may revoke the PPN DTP facility.
Such a risk could ultimately result in a tax burden for the buyer. If the facility is revoked, the DGT may collect the VAT payable from the buyer as the end consumer. This raises concerns over legal certainty for consumers. Buyers who have fulfilled their payment obligations and taken possession of the property could lose the tax benefit due to administrative errors beyond their control, such as a developer's failure to upload the BAST to Sikumbang on time.
The impact of the PPN DTP also differs between landed houses and apartments. In the landed housing segment, the incentive can help sustain sales as it aligns with demand from end consumers. By contrast, the apartment market in Jakarta is facing an oversupply. Apartment sales have declined since 2019, even before the pandemic. The extension of PPN DTP to apartments has yet to have a significant impact on sales.
One factor behind the oversupply is the high volume of purchases by investors in previous periods. Some investors are now reselling their units in the secondary market. Meanwhile, PMK No. 90/2025 limits PPN DTP eligibility to new properties handed over for the first time by developer PKPs. As a result, the facility does not cover a portion of the apartment supply available in the secondary market.
2. The 12% VAT Rate Under the HPP Law
Law of the Republic of Indonesia Number 7 of 2021 concerning Harmonization of Tax Regulations (HPP Law) provides for a VAT rate increase from 11% to 12% no later than January 1, 2025.
PMK Number 131/PMK.03/2024 introduced an adjustment mechanism using a tax base equivalent to 11/12 of the transaction value for certain goods, resulting in an effective VAT rate equivalent to 11%. Nevertheless, changes to the VAT rate can still affect market sentiment.
A higher VAT can increase both transaction and property development costs. Consumers purchasing properties outside the government-borne VAT scheme may face higher final purchase prices.
For developers, a VAT hike on construction materials such as cement, steel, and asphalt increases input tax. When purchasing power weakens, developers may not be able to pass the full cost increase on to consumers, potentially pressuring profit margins.
From a regional perspective, Indonesia’s 12% VAT rate is among the highest in ASEAN, on par with the Philippines. By comparison, Singapore applies a 9% goods and services tax, Thailand 7%, while Vietnam and Cambodia apply rates of 10%.
3. BPHTB Decentralization Under the HKPD Law
BPHTB is governed by Law of the Republic of Indonesia Number 1 of 2022 concerning Financial Relations Between the Central and Regional Government (HKPD Law)
The HKPD Law sets the maximum BPHTB rate at 5%. It establishes a minimum non-taxable item acquisition value (nilai perolehan objek pajak tidak kena pajak/NPOPTKP) of IDR 80 million for the first acquisition of property rights. This regulation increased the previous minimum NPOPTKP threshold of IDR 60 million.
BPHTB is a regional tax and an important source of LGR for regency and municipal governments. Reliance on BPHTB revenue has made some regional governments reluctant to lower rates as a means of stimulating the housing sector.
Several regions have nevertheless introduced BPHTB exemptions for first-time homebuyers. The Jakarta Provincial Government, for instance, provides a 100% BPHTB exemption under Jakarta Governor Regulation Number 23 of 2023 for a first residential property with a taxable item acquisition value (nilai perolehan objek pajak/NPOP) of up to IDR 2 billion. The Pekanbaru City Government has also introduced BPHTB exemptions for the initial registration of property rights and for upgrades to a certificate of ownership (sertifikat hak milik/SHM).
Regional policies differ, so the tax burden of buying property varies. In several areas surrounding Jakarta, including Bogor, Depok, Tangerang, and Bekasi, BPHTB of up to 5% remains a component of property acquisition costs.
The central government subsequently revoked BPHTB and PBG levies for MBR. The policy was initiated under a presidential directive and formalized through a Joint Ministerial Decree signed by Minister of Housing and Settlement Areas Maruarar Sirait, Minister of Home Affairs Tito Karnavian, and Minister of Public Works Dody Hanggodo.
The policy is based on the HKPD Law, which authorizes regional heads to grant fiscal incentives in respect of regional taxes.
The Joint Ministerial Decree establishes three primary measures, i.e., a 0% BPHTB rate for MBR, an exemption from PBG levies, and a reduction in the maximum PBG processing time from 45 days to no more than 10 working days. In several pilot areas, including Tangerang, the process can reportedly be completed within hours.
When first introduced, the policy raised concerns over its potential impact on LGR. However, the Minister of Home Affairs stated that the fiscal impact was relatively limited. In Tangerang City, for example, the LGR reduction amounted to approximately IDR 9.9 billion out of total LGR of IDR 2.9 trillion.
4. Final Income Tax on Transfer of Rights
Under Government Regulation (Peraturan Pemerintah/PP) Number 34 of 2016, property sellers are subject to final income tax under Article 4(2) at 2.5% of the gross transaction value. A reduced rate of 1% applies to affordable housing and micro housing for MBR.
The final income tax is calculated on the gross transaction value and becomes payable upon the transfer of property rights. The obligation applies regardless of whether the developer has earned a net profit or is operating at a loss.
Such a condition can put pressure on developers’ cash flow, particularly for new market entrants with limited working capital. The tax liability may arise before the developer has fully realized a profit from the project.
5. Interest-Free Loan Requirements
Article 12 of PP Number 94 of 2010 provides an exception to the imposition of interest on interest-free loans between certain parties, provided that all applicable requirements are met. Otherwise, the DGT may impute an arm’s length amount of deemed interest and impose Article 23 income tax on that amount.
Four main requirements must be satisfied. First, the funds must come from the shareholder’s own resources. The funds advanced must belong to the shareholder rather than originate from third-party borrowings. If a parent entity borrows from a bank and subsequently lends the funds to its subsidiary interest-free, the arrangement may be challenged by the DGT.
Second, all required share capital must have been fully paid. A shareholder cannot extend a loan to the company while its own obligation to contribute capital remains outstanding.
Third, the lender must not be in a loss position. The lender’s financial condition should demonstrate its capacity to provide financing without receiving interest in return. Where a company is incurring losses but continues to provide interest-free financing, the commercial rationale of the arrangement may be called into question.
Fourth, the borrower must be experiencing financial difficulties. The borrowing company must be able to demonstrate that the financing is necessary to maintain its business operations. This condition may be relevant to a property SPV that is still in the early stages of a project and has yet to generate revenue. Once the project begins generating sufficient cash flow, however, the basis for maintaining an interest-free arrangement should be reassessed.
Recommendations for the Property Sector
Tax policy for the property sector should prioritize long-term certainty rather than relying on temporary incentives. The following measures could be considered.
1. Standardize BPHTB Exemptions for First-Time Homebuyers
The government should consider BPHTB as part of a broader policy to improve access to homeownership rather than solely as a source of regional revenue.
One option would be to provide a 100% BPHTB exemption for first-home purchases, covering both landed houses and public housing with a value of up to IDR 2 billion. Such a policy should be implemented consistently across Indonesia.
Potential reductions in LGR could be offset through fiscal transfers to regional governments or alternative revenue sources, such as taxes on idle land.
2. Reduce Final Income Tax on Property Transfers
The final income tax rate of 2.5% of the transaction value can put pressure on developers’ cash flow since the tax is calculated on gross proceeds.
The government could consider reducing the rate to 1% for residential property transactions up to a specified value, such as IDR 3 billion. Such a policy could ease developers’ cash flow constraints while also encouraging transactions in the secondary property market.
3. Simplifying the PPN DTP Administrative Process
The PPN DTP remains an instrument that needs to be continued to stimulate housing demand and activity in the property sector. However, its effectiveness depends not only on the size of the budget but also on the administrative design and the alignment of the incentive with market conditions.
First, the integration of Coretax and Sikumbang. Manual BAST registration through Sikumbang should be reduced by integrating the system with Coretax. When a developer issues a tax invoice using the appropriate transaction code and enters the house identification code, the system could automatically validate the data against Sikumbang. This would allow the facility status to be verified when the tax invoice is issued, without waiting for manual document uploads.
Second, the administrative burden on developers. Administrative failures, such as delays in registering the BAST, should not immediately eliminate the PPN DTP entitlement of consumers who have fulfilled their obligations. If the error originates from the developer, administrative sanctions should instead be imposed on the developer as the PKP. Such a provision would provide better protection for consumers while encouraging developers to fulfill their administrative obligations.
Third, adjusting the BAST deadline. A BAST deadline tied to the fiscal year may conflict with construction cycles. Delays in a project could prompt developers to hand over units before they are fully ready. The government could consider allowing a three- to six-month grace period at the beginning of the following year to complete the BAST, provided that payment was fully settled during the year in which the incentive applied and all other requirements were met.
Fourth, a limited incentive for apartments in the secondary market. To address the apartment oversupply in Greater Jakarta, the government could consider a limited incentive for ready-stock units in the secondary market that have never been occupied, including units previously owned by investors. Such an expansion could be implemented selectively based on market conditions and regional characteristics to ensure that it remains aligned with the objectives of the PPN DTP program.
4. Introduce an Alternative Tax Base for Property VAT
The government could consider applying an alternative tax base to middle-income landed houses and public housing.
One option would be to set the tax base at 50% of the selling price. At a 12% VAT rate, this would result in an effective rate of 6% for consumers.
A permanent scheme of this kind could provide more certainty for both the industry and consumers than the temporary government-borne VAT incentive with specific administrative requirements.
5. Eliminate Double Taxation on DIRE
Real estate investment trusts (REITs), also known as dana investasi real estate (DIRE), can provide an alternative source of financing for developers, particularly mid-sized companies seeking to reduce their reliance on bank financing.
One of the barriers to DIRE in Indonesia is the BPHTB and VAT imposition when land or building assets are transferred to a special purpose company (SPC).
The government could consider providing tax exemptions for transfers of assets into a collective investment contract-DIRE structure where the transaction constitutes an investment restructuring rather than a commercial sale.
Removing taxes at the asset-transfer stage could improve the competitiveness of Indonesia’s DIRE market and broaden the property sector’s access to capital market investment.
6. Manage Article 23 Income Tax Exposure
Property companies can consider several approaches to managing the tax risks associated with related-party financing. First, use equity contributions. This approach is the most straightforward to avoid Article 23 income tax exposure on interest. By using equity instead of debt, funds can be injected as additional equity following approval by the GMS and the amendment to the deed. As there is no interest payment, the funding does not give rise to Article 23 income tax on interest.
Second, document financial circumstances. Where an interest-free loan continues to be used, the company should maintain documentation demonstrating that all requirements under Article 12 of PP Number 94 of 2010 have been satisfied. The document should cover the source of the shareholder’s funds, fulfillment of capital contribution obligations, the lender’s financial position, and the borrower’s need for financing. For property SPVs, cash flow projections and financial statements can help substantiate the funding requirement and the financial position when the loan was granted.
Third, establish an arm’s length interest rate. If the requirements for an interest-free loan are difficult to satisfy, the company should consider applying an interest rate consistent with the arm’s length principle. The rate should be supported by a comparable analysis and transfer pricing documentation in accordance with PMK Number 172 of 2023.
Under these circumstances, applying a relatively low but defensible interest rate supported by market data may be less risky than maintaining a 0% interest rate without sufficient justification. Therefore, the company can reduce exposure to deemed-interest adjustments, Article 23 income tax, and tax penalties.
The government could also consider reducing the Article 23 income tax rate applicable to the property sector from 15% to 2%, bringing the tax burden in line with that of the service sector. The 15% rate can put pressure on cash flow and constrain the circulation of working capital. A lower rate could reduce financing costs and support the expansion of property developments and their supporting industries.
Another option would be to introduce progressive Article 23 income tax rates based on transaction value. Rates could start at a lower level and increase according to project scale. Such a structure could provide a more proportionate tax burden for businesses while continuing to take state revenue considerations into account.
Conclusion
Tax reform in the property sector should focus on reducing transaction costs, spatial planning and licensing certainty, and expanding access to housing finance. Permanent and targeted incentives would provide greater certainty than short-term stimulus programs.
These policies should also be designed so that improved access to homeownership goes hand in hand with a broader economic base while sustaining state revenue.
Legal References
- Law of the Republic of Indonesia Number 7 of 2021 concerning Harmonization of Tax Regulations.
- Law of the Republic of Indonesia Number 1 of 2022 concerning Financial Relations Between the Central and Regional Government.
- Government Regulation Number 94 of 2010 concerning the Calculation of Taxable Income and Settlement of Income Tax in the Current Year.
- Government Regulation Number 34 of 2016 concerning Income Tax on the Transfer of Rights on Land and/or Buildings and Sale and Purchase Agreements for Land and/or Buildings and Amendments Thereto.
- Minister of Finance Regulation Number 172 of 2023 concerning the Application of the Arm’s Length Principle to Related-Party Transactions.
- Minister of Finance Regulation Number 131/PMK.03/2024 concerning the Value-Added Tax Treatment of Imports of Taxable Goods, Supplies of Taxable Goods, Supplies of Taxable Services, Utilization of Intangible Taxable Goods from Outside the Customs Area within the Customs Area, and Utilization of Taxable Services from Outside the Customs Area within the Customs Area.
- Minister of Finance Regulation Number 13 of 2025 concerning Government-Borne Value-Added Tax on Supplies of Landed Houses and Public Housing Units.
- Minister of Finance Regulation Number 60 of 2025 concerning Additional Incentive on Government-Borne Value-Added Tax on Supplies of Landed Houses and Public Housing Units for Fiscal Year 2025.
- Minister of Finance Regulation Number 90 of 2025 concerning Government-Borne Value-Added Tax on Supplies of Landed Houses and Public Housing Units for Fiscal Year 2026.
- Jakarta Governor Regulation Number 23 of 2023 concerning Exemption From Land and Building Acquisition Duty for the First Acquisition of Rights up to a Specified Taxable Acquisition Value.
- Joint Decree of the Minister of Home Affairs, Minister of Public Works, and Minister of Housing and Settlement Areas Number 600.10-4849 of 2024, Number 3015/KPTS/M/2024, and Number 141/KPTS/M/2024 concerning Support for Low-Income Households in the Implementation of the Three Million Homes Program through Land and Building Acquisition Duty Exemptions, Building Approval Levy Exemptions, and Accelerated Issuance of Building Approvals.
Also Read:
Breaking Down the Article 21 Withholding Tax Provisions
Tax Refunds Are a Right, Not a Fiscal Favor
Article 26 Income Tax: Withholding Tax on Foreign Taxpayers in Indonesia

