TaxPrime Newsletter: Minister of Finance Regulation No. 15 of 2025 or PMK 15 Tahun 2025

PMK 15 Tahun 2025 updates the provisions on Indonesia tax audits. These previously 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 latest regulation introduces new audit categories: Comprehensive Tax Audit, Focused Tax Audit, and Specific Tax Audit. These replace the older classification, which only included Office and Field Tax Audits. Each new category has a different scope and method, depending on the purpose of testing taxpayer compliance. PMK 15 Tahun 2025 also adds Carbon Tax audits to the audit scope.

Indonesia’s tax administration is becoming more digital. A major change is the implementation of the Core Tax Administration System, or Coretax, starting January 1, 2025. This shift brings several adjustments to tax processes, including audit procedures. The updated regulations align with digitalization and broader legal developments. Supreme Court Circular Letter Number 2 of 2024 (SEMA-2) also tightens evidentiary rules in tax cases. It confirms that evidence not submitted during an audit cannot be used later in the Tax Court or Supreme Court. With these changes, taxpayers should review and improve their compliance strategies to better manage audit exposure and potential disputes. Understanding and preparing for the changes under PMK 15 Tahun 2025 is key to reducing audit risks and managing potential disputes effectively.

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