PMK 15 Tahun 2025 (PMK-15): Crucial Points Regarding Regulatory Changes on Tax Audits in Indonesia

PMK 15 Tahun 2025 “PMK-15” (MoFR 15 of 2025) replaces the previous tax audit (pemeriksaan pajak) guidelines in PMK-17 jo. Article 105 of PMK-18. It shortens the tax audit timeframe and adds three new audit types: Comprehensive, Focused, and Specific. It also adds Carbon Tax audits. Under SEMA No. 2 of 2024 (“SEMA-2”), submitting data on time during a tax audit now decides whether a taxpayer can win at the Tax Court.

Key Takeaways

• PMK-15 introduces Comprehensive Tax Audit, Focused Tax Audit, and Specific Tax Audit. These replace the previous division into Office Tax Audits and Field Tax Audits.
• Carbon Tax audits join PMK-15 as a new type of tax. Article 13 (CHAPTER VI) of UU HPP governs Carbon Tax.
• A Comprehensive Tax Audit runs for up to 5 (five) months, extendable by 4 (four) months. A Specific Tax Audit runs for up to 10 (ten) working days.
• The SPHP response period is now 5 (five) working days, down from 7 (seven) working days under PMK-17 jo. PMK-184.
• SEMA-2 bars the Tax Court and/or Supreme Court from considering evidence the DGT requested but the taxpayer did not submit.
• Article 12 paragraph (4) of PMK-15 treats documents submitted after the deadline as not provided during the Tax Audit.

What Is PMK 15 Tahun 2025 (PMK-15)?

Besides supervision, the Directorate General of Taxes (“DGT”) also tests taxpayers’ compliance with tax obligations. One way it does this is through a Tax Audit. Before Minister of Finance (MoF) Regulation No. 15 of 2025 (“PMK-15”) took effect, tax audits followed MoF Regulation No.17/PMK.03/2013 (“PMK-17”) in jo. with Article 105 of MoF Regulation No.18/PMK.03/2021 (“PMK-18”).

The DGT itself has also changed. Since January 1, 2025, it has run the Core Tax Administration System (“Coretax”). As a result, tax administration procedures have changed significantly, including tax audit procedures.

PMK-15 brings several crucial changes that will significantly affect the audit process. Taxpayers must understand them, watch them closely, and prepare the right strategies. That way, the tax audit can run efficiently and end with positive results.

Read the pdf version: [English] [Bahasa Indonesia]

Types of Tax Audit Under PMK-15: Comprehensive, Focused, and Specific

PMK-15 introduces three new tax audit terms: Comprehensive Tax Audit, Focused Tax Audit, and Specific Tax Audit, whereas in previous PMK, tax audits were only divided into Office Tax Audits and Field Tax Audits. In its
explanation, a Comprehensive Tax Audit is an audit to check compliance with the fulfillment of tax obligations that covers all items in the Tax Return and/or Tax Object Notification Letter in-depth. In other words, a Comprehensive Tax Audit is what has been known as an All Taxes Audit. Then, a Focused Tax Audit is an audit to test compliance with the fulfillment of tax obligations focused on one or several items in the Tax Return and/or Tax Object Notification Letter in-depth, or in other words, a single tax audit. Furthermore, a Specific Tax Audit is an audit to check compliance with the fulfillment of tax obligations carried out specifically on one or several items in the Tax Return and/or Tax Object Notification Letter, data, or certain tax obligations in a simple manner.

Carbon Tax Audit: A New Type of Tax in PMK-15

Another interesting aspect of PMK-15 is the addition of Carbon Tax audits as a new type of tax, which is a tax imposed on carbon emissions that have a negative impact on the environment. Carbon Tax has been regulated in Article 13 (CHAPTER VI) of Law Number 7 of 2021 on Tax Regulations Harmonization (Undang-Undang Harmonisasi Peraturan Pajak/“UU HPP”).

How SEMA No. 2 of 2024 (SEMA-2) Affects the Tax Audit Process

In addition to the Coretax factor as a marker of a new era of tax administration digitalization, the issuance of Supreme Court Circular Letter No. 2 of 2024 (Surat Edaran Mahkamah Agung/“SEMA-2”) also significantly influences the tax audit process.

In this circular letter, the Supreme Court states that:

Evidence Requested by the Directorate General of Taxes but Not Provided by the Taxpayer During Tax Audit (Article 26A paragraph (4) of Law Number 28 of 2007 concerning the Third Amendment to Law Number 6 of 1983 concerning General Provisions and Tax Procedures): Evidence that is in the possession of the taxpayer and has been requested in detail and maximally within a reasonable time by the Directorate General of Taxes but still not submitted during tax audit and/or objection, cannot be considered in dispute resolution at the Tax Court and/or Supreme Court.

Article 12 of PMK-15: Official Report on Data and Document Requests

In line with SEMA-2 above, Article 12 paragraph (3) of PMK-15, states: Tax Auditors must prepare an official report on the fulfillment of obligations for the lending or requesting of books, records, and/or documents, including Electronic Data as referred to in paragraph (1) which contains information regarding taxpayers: (a) fully complying; (b) partially complying; or (c) not fully complying.

Article 12 paragraph (4): If books, records, and/or documents, including Electronic Data borrowed or requested in the request letter as referred to in paragraph (1) submitted by the taxpayer after the period as referred to in paragraph (2), considered not provided during the Tax Audit.

In the narrative above, it is clear that the enactment of SEMA-2 and the implementation of the official report on the fulfillment of tax audit data requirements will become one of the variables that significantly affect the percentage of taxpayer victories in the Tax Court process. With this regulatory change, if the taxpayer is late or fails to submit supporting data and/or documents in the Tax Audit and/or objection process, it will likely lose in the Appeal process even if the faced tax dispute is classified as a strong case.

Tax Audit Timeframe (Jangka Waktu Pemeriksaan Pajak): PMK-17 vs PMK-15

The Tax audit timeframe has also experienced significant changes.

From the comparison table of tax audit timeframes above, there are changes that will significantly impact taxpayers, namely the shorter timeframe. Therefore, taxpayers need to implement appropriate strategies, both in fulfilling data requests and providing information and in preparing written responses contained in the Tax Audit Findings Notification Letter (Surat Pemberitahuan Hasil Pemeriksaan/”SPHP”).

Pre-SPHP: Temporary Findings Discussion and the Shorter Tax Audit Timeframe

On the other hand, PMK-15 also regulates the obligation of Tax Auditors to conduct Temporary Findings Discussions (“Pre-SPHP”) in cases where tax audits are conducted to test compliance with tax obligations and do not apply to tax audits for other purposes. This can be interpreted as fairness in anticipating the short time needed to prepare written responses, as concluded above. However, technically, the time between the Pre-SPHP discussion and the final tax audit findings (“SPHP”) could be very short, as there is no strict regulation regarding the time gap between pre-SPHP and final SPHP.

Exceptions to the New Tax Audit Timeframe and Transitional Provisions

The changes in tax audit timeframes mentioned above do not apply to taxpayers who are oil and gas cooperation contract contractors with production sharing contracts with cost recovery (Production Sharing Contract Cost Recovery), refunds of tax overpayments as regulated in Article 17B of The General Tax Procedures (Ketentuan Umum Perpajakan/”KUP”) Law, Taxpayer Identification Number (“NPWP”) deletion, Taxable Entrepreneur (Pengusaha Kena Pajak/”PKP”) revocation, and other tax audits by the provisions of laws and regulations.

However, it should be understood that for types of taxes other than the Land and Building Tax (Pajak Bumi dan Bangunan/”PBB”) initiated before this Ministerial Regulation’s enactment and have not been completed, the Tax Audit completion process is carried out based on the provisions regulated in PMK-17 jo. MoF Regulation No.18/PMK.03/2021 concerning the Implementation regulation for Law Number 11 of 2020 on Job Creation in the Fields of Income Tax, Value Added Tax, and Sales Tax on Luxury Goods, as well as General Provisions and Tax Procedures.

Important Considerations for Taxpayers Facing a Tax Audit Under PMK-15

With the changes in tax audit procedures outlined in PMK-15, there are several matters that taxpayers should pay attention to, including:

FAQ: PMK 15 Tahun 2025 and the Tax Audit Timeframe