Indonesia – Exchange Of Information Under International Treaties On Tax .

On 22 May 2025, the Indonesian Directorate General of Tax (Direktorat Jenderal Pajak / “DGT”) issued Directorate General of Tax Regulation No. PER-10/PJ/2025 concerning the
Implementation of Exchange of Information Based on International Agreements (hereinafter referred to as “Regulation No. PER-10/2025”).

This new regulation aims to align Indonesia’s tax administration with global transparency standards to combat tax avoidance. It consolidates and replaces several prior rules on cross-border tax Exchange of Information.

Summary of Regulation No. PER-10/2025

The Regulation No. PER-10/2025 outlines the detailed procedures and methods for cross-border tax Exchange of Information.

The key terms set out under Regulation No. PER-10/2025: 

1. Exchange of Information 

Under Regulation No. PER-10/2025, the DGT is authorized to obtain, collect, and access information for the purpose of implementing tax laws and regulations. 

Sources of information, as regulation under the provisions of laws and regulations is derived from:

1. The exercise of taxpayer rights and/or fulfilment of tax obligations.
2. Government agencies, institutions, associations, and/or other parties.
3. Financial service institutions, other financial service institutions, and other entities particularly for accessing the financial data; and/or
4. Obtaining other Information in accordance with the applicable authority.

Such information may be exchanged to Partner Nation or Partner Jurisdiction for the purpose of executing International Treaties.  

Exchange of Information may occur through: (i) exchange upon request, (ii) spontaneous exchange, and (iii) automatic exchange.

1. Exchange of Information upon Request 

Exchange of Information upon request occurs pursuant to a request for information related to tax matters from the Competent Authority in Indonesia to the Competent Authority in a Partner Nation or Partner Jurisdiction, or vice versa.

The information which may be requested: 

1. Identity and ownership information, including beneficial owners as regulated under the laws and regulations concerning money laundering and terrorism financing crimes;
2. Accounting records;
3. Banking data;
4. Tax data; and/or
5. Other relevant information.

If the requested information is unavailable in the DGT database, it may be collected through: (i) information request to head of a financial institution, the taxpayer, and/or other parties; or (ii) by audit, in accordance with the procedures set out under the laws and regulations. 

2. Spontaneous Exchange of Information 

This Spontaneous Exchange of Information is initiated without prior request. Such exchanges carried out by the Competent Authority in Indonesia by providing information deemed relevant for tax purposes directly to the Competent Authority in a Partner Nation or Partner Jurisdiction, or vice versa, without any prior request.

The information may include:

1.  transactions or activities details between an Indonesian Taxpayer and a Taxpayer of a Partner Nation or Partner Jurisdiction.
2. regulatory updates on domestic tax regulations in Indonesia or in the Partner Nation or Partner Jurisdiction and their implementation; and/or
3. other relevant tax information that may be useful in Indonesia or in the Partner Nation or Partner Jurisdiction.

3. Automatic Exchanges

This Exchange of Information are exchanges conducted by the Competent Authority at specified times, on a periodic, systematic, and continuous basis, concerning information related to taxation matters.

The information include:

1. Tax withholding information, which related to:

1. tax withholding on income paid and/or sourced in Indonesia to a resident taxpayer of a Partner Nation or Partner Jurisdiction; or
2. tax withholding on income received by an Indonesian resident taxpayer that is paid by a taxpayer of a Partner Nation or Partner Jurisdiction and/or sourced from a Partner Nation or Partner Jurisdiction.

2. Other tax information, which are information’s excluding information on tax withholding, as defined by international treaties or agreement of the tax authorities, including: 

1. Administrative tax records from Directorate General of Taxes, for the purpose of Automatic Exchange of Information as referred to in paragraph (1)(a); or
2. Data received from the Competent Authority in the Partner Nation or Partner Jurisdiction for the purpose of Automatic Exchange of Information as referred to in paragraph (1)(b).

2. Methods of Exchange of Information 

Under Regulation No. PER-10/2025, the DGT may collect information directly overseas (or host foreign officials in Indonesia) and conduct joint audits if a taxpayers’ business or income span multiple jurisdictions.  

Regulation No. PER-10/2025 enables operational mechanisms such as: 

1. Competent Authority Meetings

These may be held in person or via remote communication (calls, video conferences, etc.) at the initiative of either the DGT or a Partner Nation’s authority.

2. Tax Examinations Abroad

Tax Examinations Abroad may be conducted abroad or within the country upon the fulfilment of the following conditions: 

1. A prior Exchange of Information was not sufficient.
2. An Exchange of Information is being carried out based on a Request between Authorized Officials, but additional urgency is required; or
3. Following up on spontaneous exchanges as referred to in Article 5 paragraph (1) of Regulation No. PER-10/2025.

3. Simultaneous Tax Examinations

These joint Tax Examinations may be conducted in the event that: 

1. there is a connection in tax matters between a Taxpayer of a Partner Nation or Partner Jurisdiction and the Directorate General of Taxes related to the tax matters referred to in point (a); and
2. there is an indication of tax avoidance and/or tax evasion.

3. Delegation of Authority and Authorized Persons

Article 12 of Regulation No. PER-10/2025 allows the Director General of Tax to delegate the authority to the Director of International Taxation or other officials on the Echelon II level to conduct: 

1. Exchange of Information as stipulated under Article 3 Paragraph (1) of Regulation No. PER-10/2025;
2. Competent Authority Meetings, Tax Examinations Abroad, and/or Simultaneous Tax Examinations as stipulated under Article 3 Paragraph (3) of Regulation No. PER-10/2025; 
3. Submission of requests for information to the heads of financial institutions, taxpayers and/or other parties as referred to in Article 4 Paragraph (3) letter a of Regulation No. PER-10/2025.

This ensures streamlined coordination and implementation of international tax agreements.

Conclusion

Regulation No. PER-10/2025 reinforces Indonesia’s commitment to international tax cooperation. By updating its legal framework, the DGT strengthens its ability to uncover tax avoidance and hidden assets while aligning its procedures with global standards.

For business, this means heightened scrutiny of cross-border transactions and greater expectations around compliance and transparency. Keeping accurate documentation and staying informed will be essential under the new regime.

For further information, please contact: 

MetaLAW, Legal & Tax Consultant, Jakarta, Indonesia 

general@metalaw.id 

1.Article 2 Paragraph (1) Regulation No. PER-10/2025  

2.Article 2 Paragraph (2) Regulation No. PER-10/2025 

3.Pursuant to Article 1 Paragraph (2) of Regulation No. PER-10/2025, International Treaties consists of: a. Double Tax Avoidance Agreement; b. Tax Information Exchange Agreement; c. Convention on Mutual Administrative Assistance in Tax Matters; d. Multilateral or Bilateral Competent Authority Agreement; e. Intergovernmental Agreement; or f. other bilateral or multilateral agreements. 

4.Article 1 Paragraph (7) Regulation No. PER-10/2025 

5.Article 4 Paragraph (2) Regulation No. PER-10/2025 

6.Article 4 Paragraph (3) Regulation No. PER-10/2025 

7.Article 1 Paragraph (8) Regulation No. PER-10/2025 

8.Article 5 Paragraph (2) Regulation No. PER-10/2025 

9.Article 1 Paragraph (9) Regulation No. PER-10/2025 

10.Article 6 Paragraph (2) (3) Regulation No. PER-10/2025 

11.Article 7 Regulation No. PER-10/2025 

12.Article 8 Regulation No. PER-10/2025 

13.Article 9 Regulation No. PER-10/2025