Indonesia is entering a more digital and internationally aligned tax compliance era. For foreign companies and multinational groups operating in Indonesia, two major developments should now be closely monitored: the implementation of Coretax DJP and Indonesia’s adoption of the Global Minimum Tax framework under PMK 136/2024.
Coretax is designed to modernize Indonesia’s tax administration by integrating core tax processes, including taxpayer registration, tax return filing, payment, audit, and collection. At the same time, Indonesia has introduced global minimum tax rules through PMK 136/2024, which applies the OECD/G20 Pillar Two framework for in-scope multinational enterprise groups.
Why This Matters for Foreign Companies
Foreign companies in Indonesia, especially those that are part of large multinational enterprise groups, need to review their tax governance, reporting structure, and internal documentation. The Global Minimum Tax is not targeted at every company, but it is highly relevant for multinational groups with consolidated annual revenue of at least EUR 750 million.
For these companies, compliance is no longer limited to ordinary corporate income tax reporting. They may also need to prepare for GloBE-related reporting, notification requirements, effective tax rate calculations, and top-up tax analysis.
Understanding Indonesia’s Coretax System
Coretax DJP is part of Indonesia’s tax administration reform. It integrates key tax administration processes into a centralized digital system, covering taxpayer registration, tax return submission, tax payment, audit, and collection.
For foreign companies, this means tax compliance will increasingly depend on accurate data, correct taxpayer access, valid authorization, and timely electronic filing. Companies should ensure their Indonesian entity has updated taxpayer data, proper access rights, and internal coordination between finance, tax, and legal teams.
What Is the Global Minimum Tax Under PMK 136/2024?
Indonesia issued PMK 136/2024 on 31 December 2024 to regulate the implementation of the Global Minimum Tax based on international agreements. The regulation adopts the GloBE framework developed by the OECD/G20 Inclusive Framework on BEPS.
Under this framework, in-scope multinational groups are generally expected to pay a minimum effective tax rate of 15% in each relevant jurisdiction. The rules include mechanisms such as Income Inclusion Rule (IIR), Undertaxed Payment Rule (UTPR), and Domestic Minimum Top-up Tax (DMTT/QDMTT).
Compliance Checklist for Foreign Companies in Indonesia
1. Confirm whether the company is part of an in-scope MNE group
Check whether the global group has consolidated annual revenue of at least EUR 750 million. If yes, the Indonesian entity may need to assess its GloBE obligations.
2. Review Indonesian entity classification
Determine whether the Indonesian company or permanent establishment is a constituent entity within a multinational enterprise group. PMK 136/2024 applies to domestic taxpayers and permanent establishments that are constituent entities of an in-scope multinational group.
3. Add GloBE taxpayer status when required
Under PER-6/PJ/2026, Wajib Pajak GloBE must submit an application to add GloBE taxpayer status no later than 9 months after the end of the first GloBE imposition year. The application is submitted electronically through the taxpayer portal.
4. Prepare GloBE tax return documentation
Wajib Pajak GloBE must submit an annual income tax return for GloBE purposes. The return may include sections for GloBE, UTPR, and DMTT, depending on the taxpayer’s position and obligations.
5. Monitor the SPT submission deadline
The annual income tax return for GloBE purposes must generally be submitted no later than 4 months after the end of the GloBE tax year. For the first GloBE imposition year, an extension of up to 2 months may be available through a notification process.
6. Prepare the GloBE Information Return
The GloBE Information Return, or GIR, must include information such as constituent entity identity, group structure, effective tax rate calculations, top-up tax calculations, and relevant GloBE elections.
7. Pay attention to GIR and notification deadlines
GIR and Notification must generally be submitted no later than 15 months after the end of the GloBE imposition year. For the first year in which the group falls within the GloBE rules, the deadline is extended to 18 months.
8. Ensure electronic submission readiness
PER-6/PJ/2026 states that GIR and Notification are submitted through the taxpayer portal or other applications integrated with DJP’s tax administration system. This makes system readiness, access authorization, and data accuracy essential.
9. Prepare payment for top-up tax where applicable
Top-up tax under IIR, DMTT, and UTPR must be paid no later than the end of the GloBE tax year. PER-6/PJ/2026 also provides specific tax account and payment codes for IIR, UTPR, and DMTT.
10. Strengthen internal tax governance
Foreign companies should coordinate with their headquarters, regional tax teams, and Indonesian advisors to align financial reporting, transfer pricing documentation, tax payment records, and GloBE calculations. This is important because DJP may request supporting documents, consolidated financial statements, transfer pricing documents, and calculation documents during supervision.
Final Thoughts
Coretax and the Global Minimum Tax mark a significant shift in Indonesia’s tax compliance environment. For foreign companies, the key is not only understanding the rules but also preparing systems, documents, taxpayer access, and internal reporting procedures early.
Companies that are part of multinational enterprise groups should review their Indonesian tax position, confirm whether GloBE rules apply, and prepare for electronic reporting through Indonesia’s tax administration system. Early preparation can help reduce compliance risks, avoid delays, and support smoother business operations in Indonesia.