As Indonesia grapples with slowing economic growth in 2026 and mounting concerns over potential foreign capital outflows from its stock market, the government has introduced a significant tax regulation in relation to the implementation of top-up tax. In 2024, the Minister of Finance (“MoF”) has issued local regulation concerning Global Minimum Tax in Indonesia through the issuance of MoF Regulation No. 136 of 2024 on Global Anti‑Base Erosion Rules Based on International Agreements (“MoF Regulation 136/2024”). Now, in 2026, the Directorate General of Taxes (“DGT”), has finally issued its implementing regulations, namely DGT Regulation No. PER‑6/PJ/2026 on Procedures for the Exercise of Rights and Fulfilment of Global Minimum Tax Obligations Based on International Agreements (“DGT Regulation 6/2026”). The DGT Regulation 6/2026 outlines several provisions for implementing GloBE in Indonesia, including formats, administrative procedures, and implementation requirements for taxpayers subject to the GloBE Rules in Indonesia.
Overview of Global Minimum Tax Regulations in Indonesia
Essentially, MoF Regulation 136/2024 establishes Indonesia’s commitment to adopt the Global Anti‑Base Erosion (“GloBE”) Rules, a framework developed by the Organisation for Economic Co‑operation and Development (“OECD”). The GloBE introduces a global minimum tax designed to prevent profit shifting and ensure multinational corporations contribute a fair share of taxation. Despite the fact that there are several critics which argue that the GloBE rules is conflicting with Indonesia’s long‑standing tax holiday incentives, which were designed to attract investment. Nevertheless, the government has opted to align with international standards, signalling their commitment to global tax reform.
In essence, the GloBE rules impose a top‑up tax whenever the effective tax rate applied to an entity within a multinational group meeting certain thresholds (“MNE Group”) falls below the prescribed global minimum rate of 15% (fifteen percent). This ensures that Indonesia remains consistent with the standard international best practices regarding tax, even as it navigates the delicate balance between investment and fiscal sustainability.
Criteria of GloBE Taxpayer
Under both MoF Regulation 136/2024 and DGT Regulation 6/2026, the criteria for determining which MNE Group that shall be subject to the global minimum tax are essentially identical. Pursuant to Article 2 of MoF Regulation 136/2024 jo. Article 3 of DGT Regulation 6/2026, constituent entities and joint venture group members are required to become GloBE taxpayers if they belong to an MNE Group that meets the following conditions:
- the annual consolidated gross revenue of the MNE Group, based on the consolidated financial statements of the ultimate parent entity (“UPE”), is at least EUR 750,000,000 (seven hundred fifty million Euro); and
- the above revenue threshold must be satisfied in at least 2 (two) out of the 4 (four) fiscal years preceding the relevant GloBE fiscal year.
Registration and Deregistration of GloBE Taxpayer Status
Upon satisfaction of the above criteria, the relevant entity di Indonesia that are included as part of the qualifying MNE Group (“GloBE Taxpayer”) is required to formally submit an application to obtain GloBE Taxpayer status for the purpose of fulfilling its tax obligations under the applicable GloBE framework in Indonesia. This application must be submitted no later than 9 (nine) months after the end of the first fiscal year in which the GloBE framework applies to the relevant MNE group. Upon approval, the Head of the local Tax Office (Kantor Pelayanan Pajak / “KPP”) where the entity is registered will issue an official notification confirming the addition of GloBE Taxpayer status.
Aside from initial registration, entities may also request revocation of GloBE Taxpayer status if their MNE Group no longer meets the prescribed thresholds and criteria. In such cases, the Head of the relevant KPP will issue a revocation notice through the Coretax system, provided the application satisfies the requirements set out under Article 6 of DGT Regulation 6/2026.
Importantly, both registration and deregistration of GloBE Taxpayer status can also be initiated ex officio by the Head of the KPP. This occurs when administrative review reveals that an entity should be classified or declassified as a GloBE Taxpayer.
Requirements as GloBE Taxpayer
Once a constituent entity or a member of a joint venture group within a MNE Group is designated as a GloBE Taxpayer, such entity becomes subject to the obligation to submit several reports and/or notification in connection with the implementation of the GloBE Rules, among others:
- Annual Income Tax Return submitted for the purpose of implementing the GloBE Rules that consist of:
- Main GloBE Annual Income Tax Return
The main GloBE Annual Income Tax Return consisted from: (a) Annual Income Tax Return for GloBE which must be completed if the GloBE Taxpayer acts as the UPE of the relevant MNE Group; (b) Annual Income Tax Return for Undertaxed Payments Rule (“UTPR”) which must be completed by the GloBE Taxpayer (other than UPE) if if there is an allocation of top-up tax based on the UTPR to the GloBE Taxpayer; and (c) Annual Income Tax Return for Domestic Minimum Top-up Tax (“DMTT”) which shall be completed by all GloBE Taxpayer in Indonesia. Furthermore, the Annual Income Tax Return for GloBE encompasses of Income Inclusion Rule (“IIR”) on a per-country or per-jurisdiction basis, the calculation of top-up tax under the UTPR on a per-country or per-jurisdiction basis, and the calculation of DMTT applicable in Indonesia.
- Annexes to the Annual Income Tax Return for the implementation of GloBE
These consist of, among others: (i) Annex I, which covers top-up taxes based on IIR and DMTT in Indonesia; (ii) Annex II, which covers top-up taxes based on UTPR allocated to the GloBE Taxpayer; and (iii) Annex III, which consists of GloBE income or loss, calculations for the Substance-Based Income Exclusion (SBIE), Additional Current Top-up Tax, and other relevant data.
The submission of the Annual Income Tax Return for the application of GloBE must be made no later than 4 (four) months after the end of the relevant GloBE fiscal year. Notwithstanding the foregoing, the GloBE Taxpayer may extend the period for filing the Annual Income Tax Return by no more than 2 (two) months in respect of the first GloBE fiscal year.
- GloBE Information Return (“GIR”)
In addition to the obligation to file an Annual Income Tax Return for GloBE implementation, a GloBE Taxpayer that is the ultimate parent entity of a MNE Group is required to submit a GloBE Information Return (GIR) to the DGT, which must be prepared in accordance with the provisions set forth under Article 12 of DGT Regulation 6/2026. The GIR shall be submitted to the DGT no later than 15 (fifteen) months after the end of the relevant GloBE fiscal year, for the first GloBE fiscal year, the submission deadline may be extended to 18 (eighteen) months after the end of such fiscal year.
In accordance with the above requirements, DGT has also provided standardized forms and templates to facilitate the implementation of the GloBE Rules in Indonesia, as set out in the appendix of DGT Regulation 6/2026.
- GloBE Notification
Subsequently, any GloBE Taxpayer that does not submit the GIR shall be required to file a notification electronically with the DGT, which shall include among others: (i) a statement of the identity of the domestic taxpayer that qualifies as the UPE; (ii) the identity of the domestic taxpayer that does not qualify as the UPE; and (iii) the identity of the party designated to submit the GIR. For the avoidance of doubt, a GloBE Taxpayer that is a member of more than one MNE Group shall be required to submit separate notifications for each such MNE Group.
The notification, in accordance with Article 15 of DGT Regulation 6/2026, shall be submitted to the DGT no later than 15 (fifteen) months following the end of the relevant GloBE fiscal year, with an extension to 18 (eighteen) months from the relevant fiscal year for the first GloBE fiscal year, which extension was not previously provided under MoF Regulation 136/2024.
Furthermore, the DGT has issued standardized forms and templates to facilitate the implementation of the GloBE Rules in Indonesia, including the format and guidance for notifications, as set forth in the appendix to DGT Regulation 6/2026.
Conclusion
The issuance of MoF Regulation 136/2024 has generated significant market reactions, presenting new challenges for entities, particularly multinational groups. Notably, this regulation also eliminates the privilege granted under the tax holiday regulation. Notwithstanding the complications under the MoF Regulation 136/2024 and the fact that it has been effective since 1 January 2025 (except for the UTPR provisions, which only take effect from 1 January 2026), the detailed implementing regulation was recently enacted in May 2026 through DGT Regulation 6/2026, thereby creating a regulatory gap and uncertainty during the preceding year. The issuance of DGT Regulation 6/2026 provides clarity in administration by establishing a clear standard for the implementation and procedures of GloBE in Indonesia, which had previously been outlined under MoF Regulation 136/2024. The promulgation of DGT Regulation 6/2026 demonstrates Indonesia’s commitment to align with evolving international taxation standards in accordance with the latest global developments.
For further information, please contact:
MetaLAW, Legal & Tax Consultant, Jakarta, Indonesia
general@metalaw.id
- Kompas, “Pertumbuhan Ekonomi RI Diprediksi Melambat Pada Kuartal II Menjadi 5,1-5,5 Persen”, https://money.kompas.com/read/2026/05/11/193122526/pertumbuhan-ekonomi-ri-diprediksi-melambat-pada-kuartal-ii-menjadi-51-55, accessed on 13 May 2026.
- Kompas, “Imbas MSCI, Rp 30 Triliun Dana Investor Asing Berpotensi Keluar dari RI”, https://www.kompas.id/artikel/sekitar-rp-30-triliun-dana-investor-asing-berpotensi-keluar-indonesia-imbas-review-msci-mei, accessed on 13 May 2026
