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 Key Challenges Under the New Framework
Despite these benefits, PMK 15/2025 introduces three distinct challenges requiring proactive response.
Strategic Preparation for Success
Managing the new audit regulation requires comprehensive preparation.
Understand PMK 15/2025 provisions — Including audit category distinctions, taxpayer rights and obligations, and standardized procedures including technology requirements and completion timelines.
Build strong administrative systems — Producing financial statements complying with Statements of Financial Accounting Standards (PSAK) and tax regulations form the foundation for successful outcomes.
Keep essential documents accessible — Tax invoices, contracts, invoices, and bank reconciliations must remain readily accessible, preferably in digital format.
Prepare transfer pricing documentation — For businesses with related party transactions, comprehensive transfer pricing documentation reduces adjustment risk.
Conduct regular internal tax reviews — Enable organizations to identify potential errors before formal audits, avoid larger penalties, prepare voluntary corrections through amended annual tax returns if needed, and identify areas prone to tax disputes.
Engage qualified tax consultants — When necessary, engaging qualified tax consultants provides valuable support for audit strategy development, representation during processes, and argument preparation if disputes arise.
As Indonesia continues evolving its tax administration toward greater efficiency and digitalization, compliance excellence serves as a strategic capability supporting business objectives through certainty and risk mitigation.
Navigate PMK 15/2025 with Confidence
Our team at TaxPrime brings extensive experience from the Directorate General of Taxes, providing us with valuable insight into tax authority perspectives and audit procedures. This understanding of both taxpayer and auditor viewpoints enables us to assist companies effectively throughout the tax audit process, from preparation and documentation strategies to representation during audit and dispute resolution when necessary.
Muhammad Noprianto
Advisor, Tax Audit & Dispute · TaxPrime
