Indonesia’s Administrative Framework for Pillar Two Implementation
Introduction
On April 20, 2026, the Director General of Taxes (DGT) issued Regulation PER-6/PJ/2026 (PER 6), establishing detailed procedural rules for implementing Indonesia’s Global Minimum Tax (Pillar Two) framework. The regulation provides the awaited administrative framework for implementing the Pillar Two rules introduced by Ministry of Finance (MoF) Regulation No. 136 of 2024, prescribing specific forms, filing timelines, payment mechanisms, and compliance obligations for in-scope multinational enterprise (MNE) groups.
With PER 6 now in force, Indonesia has moved from the policy stage to the operational stage of Pillar Two adoption, joining the growing list of jurisdictions that have translated the OECD/G20 Inclusive Framework’s GloBE Model Rules into enforceable domestic law and administrative procedures.
Background and Key Provisions
Indonesia enacted its substantive Pillar Two legislation through MoF Regulation 136/2024, which introduced the Income Inclusion Rule (IIR) and the Domestic Minimum Top-up Tax (DMTT), effective January 1, 2025, and the Undertaxed Payment Rule (UTPR) effective January 1, 2026, into the domestic tax system. However, until PER 6, there was no implementing regulation detailing how affected taxpayers should register, file returns, pay top-up taxes, or submit the GloBE Information Return (GIR).
PER 6 fills that gap comprehensively, covering the full lifecycle of GloBE compliance in Indonesia, from taxpayer registration and status management, through annual return filing and GIR submission, to post-filing adjustments, supervision, audit, and dispute resolution. The appendix to PER 6 provides the prescribed forms (including an XML-based GIR template), making it the single reference point for all procedural aspects of Pillar Two compliance in Indonesia.
Key Provisions
1. Definitions and Scope[1]
PER 6 defines several key terms, closely mirroring the OECD GloBE Model Rules’ terminology. These include Multinational Enterprise Group (MNE Group), Constituent Entity, Effective Tax Rate (ETR), Covered Tax, Substance Based Income Exclusion (SBIE), and the three charging rules, i.e., the IIR, UTPR, and DMTT. The regulation applies to constituent entities or joint venture group members established or domiciled in Indonesia that are part of an MNE Group with consolidated annual revenue of at least EUR 750 million in at least two of the four years preceding the GloBE imposition year (the tax year in which a Pillar Two top-up tax liability arises).
2. Taxpayer Registration and Status Management[2]
In-scope entities must apply electronically via the taxpayer portal to be registered as a GloBE Taxpayer within nine months after the end of the first GloBE imposition year. The application requires details of the taxpayer’s identity, the Primary Parent Entity (the group’s ultimate parent), the MNE Group, and the first GloBE imposition year. If a taxpayer fails to register, the Head of the Tax Service Office may add the status ex officio based on an administrative investigation. PER 6 also prescribes procedures for updating GloBE taxpayer data and for revoking GloBE taxpayer status if the group falls below the revenue threshold.
3. Summary of Pillar Two Administrative Compliance Obligations
| Type of Return/Report | Who Must File | Trigger Condition | Deadline | Key Information in the Return |
| GloBE Annual Income Tax Return (IIR)[3] | Indonesian-resident Ultimate Parent Entity (UPE) of an in-scope MNE Group. | MNE Group meets the GloBE threshold (≥ EUR 750 million); the entity is the group’s Primary Parent (UPE) in Indonesia. | Four months after the end of the GloBE Fiscal Year (i.e., one year after GloBE Imposition Year, with a two month extension for the first filing year). | Summary of global Pillar Two Top-up Tax computations: jurisdictional ETRs, IIR Top-up Tax per jurisdiction, UTPR Top-up Tax allocation, and the DMTT calculation for Indonesia. |
| Annual DMTT Return (Domestic Top-up Tax)[3] | Every Indonesian GloBE Taxpayer (each in-scope Constituent Entity or JV in Indonesia). | MNE Group meets the GloBE threshold (in-scope group). All Indonesian group entities must file their domestic Pillar Two return regardless of parent status. | Four months after the end of the GloBE Fiscal Year (with an additional two months for the first year, if needed). | Indonesian Pillar Two calculation: the CE’s GloBE income and Indonesia ETR, any de minimis exclusion or other safe-harbor election applied, and the resulting DMTT Top-up Tax due (if Indonesia’s ETR < 15%). |
| Annual UTPR Return[3] | Any Indonesian GloBE Taxpayer (non-UPE) that receives an allocated UTPR Top-up Tax. | The MNE Group has residual Top-up Tax not covered by the IIR/QDMTT, leading to a UTPR allocation to an Indonesian entity (the trigger occurs only if such an allocation is made). | Four months after the end of the GloBE Fiscal Year (extendable by two months for first-year filing). | Amount of UTPR Top-up Tax allocated to that Indonesian entity (per the jurisdictional allocation formula). |
| GloBE Information Return (GIR)[4] | The Indonesian UPE or an Indonesian Constituent Entity designated as the reporting CE when the group’s UPE is a foreign entity without a QCAA with Indonesia. | The MNE Group meets the GloBE threshold. If the UPE is Indonesian, it must file the GIR. If the UPE is foreign and no Qualifying Competent Authority Agreement (QCAA) covers Indonesia, one local CE must be appointed to submit the GIR. | 15 months after the end of the GloBE Imposition Year (18 months for the first imposition year). | Comprehensive group report: the identity and status of all Constituent Entities, the group ownership structure, jurisdictional ETR and Top-up Tax calculations (IIR and UTPR) for each jurisdiction, any JV Top-up Tax, the allocation of Top-up Tax by IIR/UTPR, and details of any GloBE elections made. |
| Notification[5] | Every Indonesian GloBE Taxpayer that is not itself filing a GIR. | The MNE Group meets the GloBE threshold. All local CEs must notify the DGT of the group’s designated Pillar Two filing entity. (If an Indonesian CE has submitted the GIR, it is exempt from this notification.) | 15 months after the end of the GloBE Imposition Year (+18 months for first imposition year). | Electronic notice to the DGT identifying the Indonesian UPE (if applicable), other Indonesian CEs, and the appointed GloBE filing entity. If a GloBE Taxpayer belongs to two different Pillar Two groups in the same year, it must submit separate notifications for each group. |
4. Payment and Deposit of Additional Taxes[6]
Any top-up taxes due under the IIR, UTPR, and DMTT must be paid no later than the end of the relevant GloBE tax year, using tax account code 411618 with deposit type codes 610 (IIR), 620 (UTPR), or 630 (DMTT).
Implementation Framework
All GloBE-related processes from taxpayer registration and data updates to return filing, GIR submission, and Notification are conducted electronically through the online Taxpayer Portal integrated with the DGT’s Coretax system. Returns and GIR submissions receive official electronic proof of receipt only after the system performs automated validation of the taxpayer identification number and checks for data completeness.
The DGT has broad supervisory powers to ensure compliance, including the ability to request consolidated financial statements, transfer pricing documentation, and other supporting documents used for Top-up Tax calculations. They may also conduct discussions or on-site visits, issue warnings, and carry out full tax audits. PER 6 also provides a comprehensive dispute resolution framework (aligned with Indonesia’s general tax procedures), covering self-corrections, objections, reductions or cancellations, appeals, and lawsuit procedures.
PER-6 Impact on MNE Groups
- Operational Readiness: In-scope MNE groups now have a definitive Pillar Two compliance roadmap. The prescribed forms, XML schemas, and line-by-line instructions in PER 6 will facilitate the internal processes and systems required for GloBE compliance in Indonesia.
- Revenue Protection: The DMTT ensures that Indonesia captures the Top-up Tax on low-taxed profits of domestic constituent entities before other jurisdictions can claim it through the IIR or UTPR, thereby preserving Indonesia’s taxing rights on those profits.
- Administrative Integration: By channeling all Pillar Two processes through an integrated online system (Coretax) and standardizing the GIR in an XML format aligned with the OECD template, Indonesia positions itself for the seamless automatic exchange of GIR data.
- Compliance Complexity: PER-6 introduces a significant new compliance layer. In-scope groups will need to track GloBE imposition years, GloBE tax years, manage multiple return types, prepare GIR filings in XML format, meet notification requirements, and adhere to payment deadlines alongside their regular Indonesian tax obligations.
Conclusion
PER 6 is a major development in Indonesia’s Pillar Two journey, converting the substantive GloBE rules enacted in 2024 into a fully operational compliance framework. For multinational groups with Indonesian operations meeting the EUR 750 million threshold, the regulation demands immediate attention: taxpayer registration timelines are currently active, return forms and GIR templates are now prescribed, and payment codes have been assigned.
Stakeholders, including regional and global tax teams, finance functions, and external advisors should assess their GloBE exposure in Indonesia, map the new filing and payment obligations against their existing compliance calendars, and invest in the data infrastructure needed to populate the prescribed GIR in XML format. Early preparation will be critical, particularly given that the first Pillar Two filing deadlines are approaching fast.
How A&M Can Help
A&M supports multinational groups in addressing Indonesia’s GloBE compliance requirements through comprehensive, end-to-end assistance. This includes assessing in-scope status and facilitating registration as a GloBE taxpayer, as well as preparing and filing Annual Income Tax Returns (IIR, UTPR, and DMTT) and the GIR in XML format. We also assist with post-filing adjustments and engagement with supervisory authorities, including responding to inquiries from the DGT.
We provide support in navigating both the technical and operational aspects of compliance. This includes assisting tax and finance teams in sourcing, validating, and reconciling data required for GloBE calculations; modeling effective tax rates and potential top-up tax exposures; and evaluating the applicability of safe harbor elections and transitional relief. We also help design and implement sustainable compliance processes that align tax, finance, and IT functions. In addition, we support clients in managing post-filing adjustments, regulatory reviews or audits by the DGT, and related dispute resolution processes.
Sources
[1] Article 1 of PER 6
[2] Articles 3 and 4 of PER 6
[3] Articles 7–10 and 29 of PER 6, read with Attachment G
[4] Articles 12–13 of PER 6, read with Attachment I
[5] Articles 14–15 of PER 6, read with Attachment J
[6] Article 20 of PER 6
