To comply with the evolving tax laws and regulations, as well as to harmonize the regulations governing tax audits, the Indonesian Minister of Finance has recently issued Minister of Finance (MoF) Regulation No. 15 of 2025 on Tax Audit (PMK 15). Effective February 14, 2025, PMK 15 consolidates and simplifies previous regulations on tax audits, which were previously dispersed across multiple regulations. Consequently, since the effective date of PMK 15, MoF Regulation No. 17/PMK.03/2013 (including its amendments – PMK 17/2013), MoF Regulation No. 256/PMK.03/2014 (PMK 256/2014), and Article 105 of MoF Regulation No. 18/PMK.03/2021 are revoked and replaced by the regulations contained in PMK 15. This publication will provide concise information on PMK 15 and elucidate the distinctions between it and the preceding regulations.
What’s New?
PMK 15 introduces three types of tax audits, namely: comprehensive, focused, and specific audits. Further, it also expands the criteria for tax audits. According to the previous regulations, there were 12 criteria to carry out tax audit while PMK 15 expands such criteria to 25 types. Last but not least, PMK 15 shortens the timeline for taxpayers to submit a written response to Audit Result Notification Letter (Surat Pemberitahuan Hasil Pemeriksaan or SPHP). Previously, taxpayers were required to submit a response within seven business days of receiving the SPHP . However, PMK 15 has reduced this timeline to five business days, as outlined in Article 18 paragraph (2) of the PMK.
Types of Audits
- Comprehensive Audit
This audit examines all items included in the Tax Return or Tax Objects Return (for land and buildings) in a thorough manner. The duration of this audit type is five months.
- Focused Audit
This audit concentrates on one or several items within the Tax Return or Tax Objects Return (for land and buildings) in a comprehensive manner. The duration of this audit type is three months.
- Specific Audit
This audit is conducted specifically on one or several items within the Tax Return or Tax Objects Return (for land and buildings), data, or specific tax obligations in a straightforward manner. The duration of this audit type is one month.
Scope of Audits
The types of taxes that are part of the regulations under PMK 15 are income tax, value-added tax, tax on luxury goods, stamp duty, land and building tax, sales tax, carbon tax, and other taxes that are administered by the Directorate General of Taxation in accordance with the prevailing laws and regulations.
Transitional Provisions
In light of PMK 15’s revocation of previous regulations, it incorporates transitional provisions for the ongoing tax audit commenced prior to its issuance but incomplete. The following transitional provisions apply:
- Tax audits unrelated to land and building taxes, which commenced before PMK 15’s issuance, will continue under PMK 17/2013 and general tax provisions.
- Tax audits pertaining to land and building taxes, which commenced before PMK 15’s issuance, will continue under PMK 256/2014.
Conclusion
PMK 15, a component of the MoF’s initiatives to harmonize tax audit regulations with the Harmonization of Tax Regulations Law (UU HPP), aims to streamline the audit process, clarify guidelines, and enhance compliance with tax regulations. Additionally, PMK 15 establishes a standard for audits that regulates, among other aspects, the educational background of investigators and their integrity. The eventual issuance of PMK 15 is anticipated to provide legal certainty for tax audits, safeguarding both the State’s interests and those of taxpayers.
For Further Information, Please Contact:
MetaLAW, Legal Consultant, Jakarta, Indonesia
general@metalaw.id
1 Article 42 paragraph (2) of PMK 17/2013
