In this article
By Bobby Savero
Advisor, Transfer Pricing and International Tax
The Directorate General of Taxes (DGT) has issued PER-6/PJ/2026, the critical implementing regulation operationalizing the administrative obligations of the Global Minimum Tax (GMT) regime under PMK-136/2024. Rather than adapting existing corporate income tax workflows, the DGT has established a distinct procedural ecosystem that introduces entirely new compliance mechanisms for GMT.
Under PMK 136/2024, a Constituent Entity is in scope as a GloBE Taxpayer (Wajib Pajak GloBE) if its multinational enterprise (MNE) Group has consolidated gross revenue of at least EUR 750 million in at least 2 of the 4 fiscal years preceding the Tahun Pengenaan GloBE (GloBE year). If your group meets that threshold for a 2025 Tahun Pengenaan GloBE, you are in scope now.
The scope applies equally to Joint Ventures (JV): if you are a JV company or member of a JV group that meets the threshold, you are also impacted and carry the same registration, payment, filing, and reporting obligations.
PER-6/PJ/2026 introduces a three-tier year hierarchy that governs all administrative deadlines under the Global Minimum Tax Indonesia regime:
Differentiating these terms is a starting point for GMT compliance; the full mapping is set out in
PER-6/PJ/2026 creates a standalone obligation to register as a GloBE Taxpayer under the GloBE Rules Indonesia. In-scope Constituent Entities and JV members must apply for GloBE status electronically through the Portal Wajib Pajak, no later than 9 months after the end of the first Tahun Pengenaan GloBE. A failure to apply allows the Tax Office (KPP) to assign the status ex officio [1].
[1] Also notable: the same chapter governs two related status actions through the Portal Wajib Pajak: change of data (perubahan data), to update the taxpayer’s, UPE’s, or MNE Group’s identity, address, or administrative contact; and revocation (pencabutan status), where the Group ceases to meet the EUR 750 million threshold. Both can be done on application or ex officio; revocation is not automatic on existing scope, so a group that falls out of scope should file proactively.
The regulation provides that status notification is issued automatically by the system on receipt, but sets no mandated response time, so file early rather than at the deadline.
The regulation introduces three new annual return formats under PMK 136/2024: SPT Tahunan PPh GloBE, SPT Tahunan PPh DMTT, and SPT Tahunan PPh UTPR, each filed via the Portal Wajib Pajak. The SPT is due 4 months after the end of the Tahun Pajak GloBE, with a one-time 2-month extension available for the first implementation year (notification must be lodged before the original deadline).
Regarding payment procedures, the regulation introduces dedicated payment codes: Top-up Tax under Global Minimum Tax is paid using Tax Account Code (KAP) 411618, with the Deposit Type Code (KJS) distinguishing the mechanism: 610 (IIR), 620 (UTPR), 630 (DMTT). Top-up Tax must be paid by the end of the Tahun Pajak GloBE. Refer to Annex C and Annex D for the detailed payment codes and the deadline calendar.
Separate from the SPT, the regulation establishes the GloBE Information Return (GIR) and the Notification as standalone reporting obligations under the GloBE Rules Indonesia, each with its own form, channel, and deadline. Both are due 15 months after the end of the Tahun Pengenaan GloBE — 18 months for the first year. The GIR is filed by the resident UPE in XML format; a Constituent Entity that files a GIR is exempted from the Notification. Note that these deadlines anchor on the Tahun Pengenaan GloBE, not the Tahun Pajak GloBE used for the SPT and payment.
Beyond registration and filing requirements of Global Minimum Tax Indonesia, PER-6/PJ/2026 also codifies the post-filing adjustment mechanism (Additional Current Top-up Tax recalculation; EUR 1 million materiality threshold for covered-tax decreases) and dedicated supervision, audit, and dispute procedures — with supervision applying even to entities not yet registered. While not the primary focus of this Alert, factor these into your GMT Indonesia compliance planning.
For in-scope groups, we recommend the following sequence:
“A key point to flag with stakeholders: registration, SPT filing, and GIR / Notification are due regardless of safe harbour outcomes under the GloBE Rules Indonesia framework. A safe harbour reduces the computational burden for a jurisdiction; it does not switch off the administrative obligations for Global Minimum Tax compliance.”
Senior Advisor
Specialized tax expertise with 7 years as a DGT employee. Rising Star Transfer Pricing Expert by World TP, Rising Star Awards Asia Pacific 2021 from International Tax Review (ITR).
Wide experience in Transfer Pricing compliance, audit, Disputes, APA, and MAP. Holds Legal Representative License for tax appeal and received APCIT certification from IBFD.
Advisor
With 15 years of experience in tax administration, Bobby Savero provides expert advisory in international tax and transfer pricing, with deep knowledge of GMT and GloBE rules. Academic credentials from the International Tax Center at Leiden University and IBFD.
