Indonesia – Guidelines For Tax Court Proceedings.
Director General of Taxes Circular Letter No. SE-6/PJ/2026, dated 1 July 2026, provides new guidelines for handling appeal and lawsuit proceedings before the Tax Court. The Circular Letter aims to make the process clearer and more consistent and to improve the way tax disputes are handled by the Directorate General of Taxes (DJP). It also updates the previous guidelines under Circular Letter No. SE-65/PJ/2012, including changes related to the officials responsible for handling tax disputes, the use of the CORETAX DJP system, and the administration of proceedings through e-Tax Court.
Under the new guidelines, the process covers several steps, including preparing and submitting an Appeal Explanation Letter (Surat Uraian Banding) or Response Letter (Surat Tanggapan), appointing a hearing team, preparing a summary of the dispute and a strategy for handling the case, attending hearings, examining evidence, and managing case documents. The Appeal Explanation Letter and Response Letter must respond to the taxpayer’s arguments based on the relevant facts, evidence, and applicable laws and regulations.
The Circular Letter also sets deadlines for submitting these documents. An Appeal Explanation Letter must generally be submitted within three months from the date the request is sent, while a Response Letter must be submitted within one month. The documents may be submitted to the Tax Court by post, courier, or through the e-Tax Court system. Supporting documents must also be properly scanned and uploaded to the CORETAX DJP system.
For the hearings, a hearing team of at least two DJP employees will be appointed for each panel of judges or single judge. The team will prepare the case summary and strategy, collect relevant information and documents, attend hearings, present evidence and explanations, and, where necessary, present experts or witnesses. The team must also prepare a hearing report after each hearing and a summary of the proceedings once the hearings are completed.
The Circular Letter also emphasizes proper management of case documents. Hardcopy documents received during the proceedings must be scanned, while scanned documents and other relevant electronic documents must be uploaded to the CORETAX DJP system. The detailed process for handling appeals and lawsuits before the Tax Court will continue to follow the applicable Standard Operating Procedures.
Finally, SE-6/PJ/2026 revokes and replaces SE-65/PJ/2012. Therefore, Tax Court appeal and lawsuit proceedings should now be handled in accordance with the new guidelines. This also applies to ongoing proceedings that were previously handled under SE-65/PJ/2012 but have not yet been completed.
For Further Information, Please Contact:
MetaLAW, Legal Consultant, Jakarta, Indonesia
general@metalaw.id
