TaxPrime Newsletter: Minister of Finance Regulation No. 15 of 2025

Minister of Finance Regulation No. 15 of 2025 (“PMK-15”) has updated the provisions regarding tax audits that previously still referred to MoF Regulation No.17/PMK.03/2013 (“PMK-17”) and Article 105 of MoF Regulation No.18/PMK.03/2021 (“PMK-18”). This change introduces new tax audit categories, namely Comprehensive Tax Audit, Focused Tax Audit, and Specific Tax Audit, replacing the previous tax audit classification that only consisted of Office and Field Tax Audits. Each category has different scope and methodology, tailored to the objective of testing taxpayer compliance. Additionally, PMK-15 also regulates the addition of Carbon Tax audits, which becomes part of the new tax audit scope.

With the development of Indonesia’s tax administration becoming increasingly digital, especially through the implementation of the Core Tax Administration System (“Coretax”) starting January 1, 2025, tax administration processes have experienced various significant adjustments, including Tax Audit procedures. These regulatory changes not only adapt to the tax digitalization system but also respond to broader legal developments. Furthermore, Supreme Court Circular Letter Number 2 of 2024 (“SEMA-2”) tightens evidentiary procedures in tax cases, affirming that evidence not submitted during tax audits cannot be considered in dispute resolution processes at the Tax Court or Supreme Court. With these various changes, taxpayers are expected to adjust their compliance strategies to be more effective in dealing with tax audits and anticipating tax dispute risks.

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