Introduction

On August 5, 2025, Indonesia’s Directorate General of Taxes (DGT) issued Regulation Number PER-15/PJ/2025 (PER 15), which took effect immediately on its issuance date.^[1] Serving as the implementing regulation for Regulation Number 37 of 2025 (PMK 37)^[2] issued by Minister of Finance (MoF), PER 15 provides detailed operational procedures for the collection, deposit, and reporting of Article 22 Income Tax on income earned by domestic traders through electronic trading platforms.

The regulation offers practical guidance for e-commerce platforms and digital intermediaries appointed as tax collectors, including clear thresholds, notification requirements, documentation standards, and provisions regarding appointment, revocation, and ongoing compliance obligations for these platforms.

Key Provisions

1. Thresholds for Appointment ^[3]

A platform can be appointed as an Article 22 income tax collector if it:

• Uses an escrow account to collect income from domestic sellers; and
• Meets the following thresholds related to transactions or user traffic from Indonesia:
  • Transaction value exceeding IDR 600 million annually or IDR 50 million in one month; and/or
  • User traffic exceeding 12,000 visits annually or 1,000 visits in one month

These criteria apply to both domestic and certain foreign platforms, providing clear guidelines for all. A platform that has not yet been appointed as an income tax collector can notify the DGT if it wishes to be appointed.

2. Appointment and Revocation Procedures ^{[4] [5] [6]}

The DGT issues decision letters for appointment of tax-collecting platforms and the obligation to collect Article 22 Income tax starts from the beginning of the following month. Domestic platforms are required to use their existing tax identification number (NPWP) whereas appointed foreign platforms will be granted with a tax identification number (NIP) for inclusion in official tax collection records.

Appointments can be revoked if criteria are not met, or not met upon request, with clear notification and transition rules. Appointed platforms must notify the DGT — with supporting documents — either directly or via the Taxpayer Portal. Revocation is effective from the date the decision letter is issued by the DGT. In the case of an appointed foreign platform, the revocation will trigger an ex-officio revocation of its tax identification number in accordance with applicable regulations.

3. Exemptions for Government Transactions ^[7]

PER 15 clarifies that for transactions with government institutions made through e-commerce platforms and settled by government credit card or cash, Article 22 income tax is collected by the platform, not the government institution, preventing double taxation on the same transaction.

4. Tax Collection, Deposit, and Reporting Procedures ^[8]

Appointed platforms must perform tax collection, deposit, and reporting precisely as mandated by law. The tax withheld can be credited against a taxpayer’s final or annual income tax liability, supporting easier reconciliation and compliance.

In the event of revocation, platforms are still required to deposit and report any tax collected prior to revocation by the 15th and 20th of the following month, respectively.

5. Transitional Provisions and Reporting ^[9]

PER 15 mandates that for the 2025 tax year, all relevant documents, billing, and status changes be submitted promptly—within one month after a platform is appointed as a tax collector. Billing documents (electronic invoices) generated by the platforms must include seller’s name and tax identity information. If these details cannot be incorporated automatically, alternative documentary evidence confirming that the tax identification number matches the ones in the DGT system will be acceptable.

Regulatory Implications and Operational Impact

By introducing explicit criteria, PER 15 reduces ambiguity for platforms regarding their obligations and eligibility. It focuses on platforms with substantial traffic or transaction volume, thus preserving MSMEs and small vendors from excessive compliance burden.

The regulation also improves government oversight by detailing revocation procedures and requiring systematic updates and notifications regarding changes in platform status or trader information.

Additionally, exemption for government transactions acknowledges unique public sector payment methods, simplifying compliance for platforms serving these clients.

How A&M Can Help

A&M can help e-commerce platforms and businesses adapt quickly to the new compliance requirements under PER 15 by offering:

• Regulatory Impact Assessment: Identify how the regulation affects your platform’s operations, eligibility, and compliance risks, both for domestic and foreign players.
• Process and System Alignment: Tailor your onboarding, KYC, transaction handling, and reporting processes to meet the new documentation and notification requirements.
• Implementation Support: Develop clear procedures for Article 22 tax collection, deposit, and reporting, including exemptions and revocation scenarios.
• Liaison With Tax Authorities: Prepare and submit required applications, notifications, and supporting documents; facilitate engagement with the DGT.
• Ongoing Compliance Monitoring: Keep your tax processes and systems aligned with evolving regulations and thresholds.

With proven expertise in Indonesian tax and e-commerce operations, A&M enables businesses to comply efficiently while identifying operational efficiencies and growth opportunities.

Sources

^[1] Indonesia Directorate General of Taxes, Regulation Number PER-15/PJ/2025, August 5, 2025, https://datacenter.ortax.org/ortax/aturan/show/26377

^[2] Abhijit Ghosh et al., “PMK 37/2025: New Indonesia Regulation on Withholding of Article 22 Income Tax by E-Commerce Platforms,” Alvarez & Marsal, July 23, 2025, https://www.alvarezandmarsal.com/thought-leadership/pmk-37-2025-new-indonesia-regulation-on-withholding-of-article-22-income-tax-by-e-commerce-platforms; Indonesia Minister of Finance, Regulation 37 of 2025, July 14, 2025, https://www.pajak.go.id/id/artikel/pmk-372025-kesetaraan-pajak-pedagang-online-dan-offline#:~:text=PMK%2037/2025%2C%20Kesetaraan%20Pajak,dan%20Offline%20%7C%20Direktorat%20Jenderal%20Pajak

^[3] Article 4 of PER 15

^[4] Articles 2 and 6 of PER 15

^[5] Articles 3 and 7 of PER 15

^[6] Articles 3 and 7 of PER 15

^[7] Article 3 of PER 15

^[8] Articles 9 and 10 of PER 15

^[9] Article 9 of PER 15