Baeti RomaniahTax Audit & Dispute Advisor

PMK 28/2026 transfer pricing regulations from Indonesia's Ministry of Finance introduce a 5% tax correction threshold that directly affects MNEs' access to preliminary VAT refunds and Kriteria Tertentu status. Companies with related-party transactions in Indonesia must now review whether their transfer pricing framework can withstand the new threshold — a single qualifying correction restarts a

In today’s business landscape, systems and standards have evolved into key indicators of a company’s commitment to quality management assurance. In addressing the post-Customs Audit Report (Laporan Hasil Audit / LHA) process, system integration plays a crucial role in delivering positive outcomes for companies. By integrating internationally recognized quality management practices, such as ISO 9001,

PMK 15/2025 (Ministry of Finance Regulation Number 15 of 2025) fundamentally restructures Indonesia's tax audit framework, unifying three prior regulations and introducing shorter audit timelines, digitalized procedures through Coretax, and expanded audit criteria. For businesses operating in Indonesia, understanding PMK 15/2025 is no longer optional: the regulation directly impacts how quickly companies must respond, what

Advance Pricing Agreement Indonesia is increasingly recognized as one of the most effective proactive strategies for Multinational Enterprises (MNEs) to manage transfer pricing risk before disputes arise. As the volume of transfer pricing controversies in Indonesia continues to grow, MNEs with cross-border operations face mounting pressure to move beyond reactive documentation and toward preventive certainty.

Responding to SPHP (Surat Pemberitahuan Hasil Pemeriksaan) within the 5-day deadline under PMK 15/2025 is one of the most time-sensitive challenges businesses face during a tax audit in Indonesia. The regulation has eliminated the previous 3-day extension window, making it critical for taxpayers to know exactly how to respond to SPHP effectively and on time.

Since February 1, 2025, PMK 15 of 2025 has reshaped how the Directorate General of Taxes (DGT) conducts tax audits in Indonesia — replacing the old 12-month timeline with three faster audit categories, tightening the SPHP response window, and pushing document submission through Coretax. This FAQ walks through what changed, why it matters, and how

Ministry of Finance Regulation Number 15 of 2025 (PMK 15/2025) has fundamentally altered Indonesia's tax audit framework, creating both opportunities and challenges for taxpayers. Professional tax practitioners have identified key complexities arising from these regulatory changes and outlined strategic approaches for businesses to manage these changes effectively, supporting better business planning and financial management. Three

Protect your business from the new tax audit regime under PMK 15 Tahun 2025. Learn why meticulous tax documentation and bookkeeping are your primary defense to avoid substantial tax adjustments and penalties.

Understand the changes brought by PMK 15 Tahun 2025 in tax audit regulations. Discover how it benefits businesses in Indonesia.

Tax disputes are inevitable under Indonesia’s self-assessment system. Discover how to build effective mitigation strategies, including proactive planning, digital documentation, and internal reviews, to minimize adverse audit findings and manage disagreements with the DGT.