The Government of the Republic of Indonesia, through the Ministry of Finance, has made the latest breakthrough by unifying the implementing regulations related to the core tax administration system, by issuing Minister of Finance of the Republic of Indonesia Regulation No. 81 of 2024 concerning Tax Provisions in the Context of Implementing the Tax Administration System (“MoF Regulation No. 81/2024“) on 18 October 2024. MoF Regulation No. 81/2024 will be effective starting from 1 January 2025.
In the spirit of copying the omnibus law and the tax harmonization law, MoF Regulation No. 81/2024 annuls and revokes several provisions under 42 (forty-two) previous Minister of Finance regulations. Even though it seems major, the contents under MoF Regulation No. 81/2024 merely restate the previous regulations by making several adjustments, most of which are minor. This article will outline several major changes that are worth noting under MoF Regulation No. 81/2024.
Tax Payment and Deposit Deadline
MoF Regulation No. 81/2024 has extended the maximum payment and deposit deadlines for several types of taxes as regulated in the Minister of Finance of the Republic of Indonesia Regulation No. 242/PMK.03/2014 on Procedures for Payment and Deposit of Taxes (“MoF Regulation No. 242/2014“), from what was previously shall be done no later than the 10th of the following month to become no later than the 15th of the following month after the tax period ends. To summarize, the deadline for payment and deposit of tax in MoF Regulation No. 81/2024 is as follows:
| No. | Type of Tax | Before (MoF Regulation No. 242/2014) | After(MoF Regulation No. 81/2024) |
| Income Tax Article 4(2) which is deducted by the tax withholding agent | Date 10 (ten) of the following month | Date 15 (fifteen) of the following month | |
| Income Tax Article 4(2) paid by the taxpayer | Date 15 (fifteen) of the following month | ||
| Income Tax Article 15 yang which is deducted by the tax withholding agent | Date 10 (ten) of the following month | Date 15 (fifteen) of the following month | |
| Income Tax Article 15 paid by the taxpayer | Date 15 (fifteen) of the following month | ||
| Income Tax Article 21 | Date 10 (ten) of the following month | Date 15 (fifteen) of the following month | |
| Income Tax Article 22 | Categorized into: For imports are paid at the same time as payment of import duties or completion of import customs notification documents (if import duties are waived); For imports collected by the Directorate General of Customs and Excise are deposited within 1 working day after the tax is collected; For collections made by authorized budget users or officials signing payment orders, they are deposited on the same day as payments to taxable entrepreneurs partnering with the government;collected by the expenditure treasurer, shall be deposited no later than 7 days after the date of payment for delivery of goods financed from state/regional expenditure; The collection is carried out by certain corporate taxpayers as tax collectors, on the 10th of the following month. | Date 15 (fifteen) of the following month | |
| Income Tax Article 23 | Date 10 (ten) of the following month | Date 15 (fifteen) of the following month | |
| Income Tax Article 25 | Date 15 (fifteen) of the following month | Date 15 (fifteen) of the following month | |
| Income Tax Article 26 | Date 10 (ten) of the following month | Date 15 (fifteen) of the following month | |
| Value-Added Tax (VAT) | Categorized into: For imports are paid at the same time as payment of import duties or completion of import customs notification documents (if import duties are waived); For imports collected by the Directorate General of Customs and Excise are deposited within 1 working day after the tax is collected; For the use of intangible taxable goods or taxable services from outside the customs area no later than the 15th of the following month; For self-building activities, no later than the 15th of the following month;For collections made by the official signing the payment order, it is deposited on the same day as the payment to the taxable entrepreneur partnering with the government; collected by the expenditure treasurer, shall be deposited no later than 7 days after the date of payment to taxable entrepreneurs partnering with the government; the collection of which is carried out by a VAT collector appointed other than the Government Body, is deposited no later than the 15th of the following month. | Date 15 (fifteen) of the following month |
Value-Added Tax (VAT) Reporting Deadline for Electronic System Operators
MoF Regulation No. 81/2024 tightens the obligations for value-added tax collectors for trade via electronic systems which were previously regulated in the Minister of Finance of the Republic of Indonesia Regulation No. 60/PMK.03/2022 on Procedures for the Appointment of Collectors and for the Collection, Deposit, and Reporting of Value-Added Tax for the Utilization of Intangible Taxable Goods and/or Taxable Services from Outside of the Customs Area within the Customs Area via Trade through Electronic Systems (“MoF Regulation No. 60/2022”). Previously under MoF Regulation No. 60/2022, the collectors of VAT on trade through electronic systems are required to report VAT which has been collected on a quarterly basis for the period of 3 (three) tax periods by the latest at the end of the subsequent month. However, MoF Regulation No. 81/2024 changes this obligation to be carried out on a monthly basis by the latest at the end of the subsequent month.
Signature for the Tax Return
Previously under the Minister of Finance of the Republic of Indonesia No. 243/PMK.03/2014 2014 on Tax Return as amended, signing the tax return can be done by signing with a stamp. However, MoF Regulation No. 81/2024 strictly narrows the procedures for signing tax returns by removing stamp signatures from options, so that signatures on tax returns can only be done by means of a wet-ink signature or digital signature.
Electronic Filing
In line with the digital era, MoF Regulation No. 81/2024 reiterates that the fulfilment of tax obligations should be done electronically through DGT’s website, other websites, or applications that were integrated with DGT’s system or contact center. MoF Regulation No. 81/2024 limits manual (offline) submission only for certain circumstances such as there is no supporting infrastructure yet in the area of the taxpayers, technical errors with the system, or in the event of natural disasters. However, Article 168 paragraph (1) of MoF Regulation No. 81/2024 still provides a post (mailing) mechanism for the submission of annual tax return.
Conclusion
In conclusion, MoF Regulation No. 81/2024 intends to provide streamlined regulations concerning core tax administration systems. The regulation is issued in the hope of providing more ease to the taxpayers in fulfilling their tax obligations in Indonesia by referring to just only one regulation. The intention is good, however, in practice, we believe this may create some stirs amongst the practitioners (and the taxpayers) as they need to study the unified regulations under MoF Regulation No. 81/2024. Even though it seems that MoF Regulation No. 81/2024 does not create major changes, the number of revoked regulations and the number of pages of the regulation may seem daunting to taxpayers. Hopefully, the intention of the government in issuing this regulation will be achieved after the taxpayers take some time to re-study the regulation. The process can also speed up through the workshops/training/socialization provided by the MoF.
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