Introduction

On September 24, 2025, Indonesia’s Directorate General of Taxes (DGT) issued Regulation Number PER-18/PJ/2025 (PER-18)^[1], which took effect immediately. Serving as the implementing regulation for Regulation Number 15 of 2025 (PMK-15)^[2] issued by Minister of Finance (MoF), PER-18 provides further explanations on the concrete data that can lead to the Specific Tax Audit (Pemeriksaan Spesifik) process. The regulation specifies the concrete data obtained or held by the DGT that requires simple testing through the Specific Tax Audit process.

Key Highlights

Definition of Concrete Data^[3]

Concrete data is data related to taxation obtained or held by the DGT in the form of:

• Tax Invoices approved in the DGT system but not reported in Value Added Tax (VAT) returns.
• Withholding tax slips that have not been reported in monthly Income Tax returns.
• Transaction evidence or tax data to calculate taxpayer obligations as follows:
  • Excess of compensation in the VAT returns that is not supported by a VAT overpayment position reported in prior VAT returns;
  • Recalculation of input VAT as a deduction from output VAT by a Taxpayer who is not entitled to use the input VAT crediting guideline for VAT entrepreneurs conducting both taxable and non-taxable deliveries;
  • Prepaid VAT that is not paid or is underpaid;
  • Utilization of tax incentives not in accordance with the regulations;
  • Input VAT crediting not in accordance with the regulations;
  • Underreported income tax based on withholding tax slips held by the DGT and/or errors related to the use of the deemed net income calculation norm;
  • Final and binding tax assessments, decisions, or verdicts that can be used to calculate unreported or underreported tax obligations in the Tax Return; and/or
  • Data or information which can be used to calculate the taxpayer’s obligations that was requested through a Request for Explanation of Data and/or Information Notice (SP2DK), where the taxpayer had agreed in the signed minutes to fulfil the obligations but has not done so within the agreed deadline.

Specific Tax Audit Process

Concrete data mentioned above will be followed up through supervision and/or Specific Tax Audit.^[4] Pursuant to Article 1(9) of PMK-15, the Specific Tax Audit is a type of tax audit carried out in a simple manner, focusing only on one or several items in the tax return, certain data, or certain tax obligations.

The Specific Tax Audit should be completed within one month since the tax audit instruction letter is delivered to taxpayers.^[5] However, if the Specific Tax Audit is related to concrete data, the timeline shall be as follows:^[6]

• Testing phase: maximum 10 working days; and
• Closing conference and reporting: maximum 10 working days.

Further, certain rights of the taxpayer (e.g., Preliminary Findings Discussion including submission of supporting documents and presenting witnesses, expert, or third parties, Quality Assurance review) do not apply when the audit is a Specific Tax Audit, because of its simpler nature.

A&M Insight

PER-18 strengthens the DGT’s supervision procedures by explicitly categorizing certain items as concrete data, which were previously often addressed through a SP2DK, into the Specific Tax Audit process. This change provides a clearer legal procedure, as the outcome of a tax audit is a tax assessment letter, which is more binding than the Report on the Results of SP2DK. It is important to note, however, that a Specific Tax Audit does not close the fiscal year as a whole; it only addresses specific items within a given fiscal year, leaving other items potentially subject to a future tax audit.

We encourage taxpayers to review their compliance positions carefully and assess whether any of these “specific items” may impact their business. A&M would be pleased to discuss how these changes could affect your company and support you in preparing a proactive response.

[1]Directorate General of Taxes, PER-18/PJ/2025 regarding Concrete Data, issued September 24, 2025, Ministry of Finance Legal Documentation and Information Network, https://jdih.kemenkeu.go.id

[2]Minister of Finance, PMK 15 Year 2025 regarding Tax Audit, issued February 10, 2025, Ministry of Finance Legal Documentation and Information Network, https://jdih.kemenkeu.go.id

[3]Article 2 of PER-18

[4]Article 3 of PER-18

[5]Article 6 Paragraph (2) of PMK-15

[6]Article 6 Paragraph (4) of PMK-15