1. What’s New with Minister of Finance Regulation No. 15 of 2025?
Effective 14 February 2025, the Indonesian Ministry of Finance issued Regulation No. 15 of 2025 (Peraturan Menteri Keuangan/PMK 15/2025), which fundamentally changes the Indonesia tax audit procedure, how tax audits are categorized and conducted. Previously, audits were broadly divided into “field audits” and “office audits” which often created confusion due to overlapping scopes and vague timelines. Under the new framework, these outdated terms are replaced with three clearer and more structured audit types, each with its own scope and timeline.
A comprehensive audit is the broadest type of examination. It covers an entire set of tax filings, such as the Annual Tax Return (Surat Pemberitahuan Tahunan/SPT) or the Land and Building Tax Return (Surat Pemberitahuan Objek Pajak/SPOP).
- Timeline: The Directorate General of Taxes (Direktorat Jenderal Pajak/DGT) is given up to five months to conduct the audit testing, followed by 30 working days to prepare and issue the audit report.
- Purpose: This type of audit is typically applied when there are major discrepancies across multiple tax obligations, requiring a holistic review of a company’s compliance.
A focused audit is narrower in scope. Instead of reviewing the entire return, it zooms in on specific tax items that raise red flags.
- Timeline: The testing period lasts for three months, with an additional 30 working days for the issuance of the audit report.
- Examples: This may include situations where the DGT identifies irregularities in Value Added Tax (VAT/ Pajak Pertambahan Nilai – PPN) credits, discrepancies in withholding tax reports, or unusual transactions in income tax filings.
The specific audit is designed to handle cases where only one or a few issues need clarification. It is the most streamlined form of audit.
- Timeline: Normally, the testing period is limited to one month, followed by 30 working days for reporting.
- Accelerated Cases: In situations where the DGT possesses concrete evidence—such as unreported invoices, undeclared sales, or mismatches with third-party data—the timeline may be shortened further to 10 working days of testing plus 10 working days for reporting.
- Purpose: This ensures faster resolution of simple yet urgent compliance issues, minimizing disruption for businesses.
For multinational corporations and groups with related party transactions, transfer pricing reviews are often more complex. Under the new regulation, the testing phase for these audits may extend up to four months. This is a reduction from the previous six-month period, streamlining the process while still providing sufficient time for detailed analysis of cross- border transactions.
Why This Change Matters
The new framework of Indonesia tax audit procedure under PMK 15/2025 provides greater clarity, predictability, and efficiency. By setting clear categories and timelines, the regulation reduces uncertainty for taxpayers and allows businesses to better prepare for potential audits. For the Directorate General of Taxes, it ensures resources are allocated more effectively, focusing on risk-based audits rather than broad and overlapping reviews.
Key Takeaway for Businesses: Companies operating in Indonesia should review their tax compliance frameworks and internal documentation processes to align with these new audit structures. Clear timelines mean less room for delay, so proactive readiness is essential to minimize risks.
2. Key Tax Audit Procedural Changes
Under the new regulation, before the Directorate General of Taxes finalizes its audit findings, tax auditors must conduct what is called a Temporary Findings Discussion (Pembahasan Temuan Sementara). This session allows the taxpayer and their representatives to review the preliminary issues raised during the audit process. Importantly, this step gives businesses an opportunity to provide supporting documents, clarify misunderstandings, and even correct minor reporting errors before the findings are officially recorded. From a compliance perspective, this increases transparency and reduces the risk of unnecessary disputes, since both parties can align early on the facts of the case.
The timeframe for taxpayers to submit written responses to the Notice of Tax Audit Findings (Surat Pemberitahuan Hasil Pemeriksaan) has been reduced from seven working days to five working days. No extensions are permitted under the new regulation. This change requires companies to be more proactive in preparing documentation and engaging their finance teams or tax advisors during the audit process. It also emphasizes the importance of maintaining well-organized records year-round, as delays or incomplete responses may increase the risk of disputes or penalties.
When an audit is initiated, taxpayers now have a maximum of one month from the date of notification to provide all requested documents. This includes invoices, contracts, bank records, payroll data, and any other supporting financial documents relevant to the scope of the audit. Exceptions are permitted only in two cases:
- If the documents are genuinely not yet available, or
- If the Directorate General of Taxes requests additional documents later in the process.
In those cases, documents may still be submitted until before the Closing Conference (Pembahasan Akhir Hasil Pemeriksaan) minutes are signed. This stricter one-month rule is designed to reduce audit delays and ensure that cases progress in a timely and structured manner.
The new regulation also emphasizes a digital-first approach through the integration of the CoreTax Administration System. Taxpayers are encouraged to submit documents electronically, and electronic signatures are recognized as valid for many parts of the process. However, some communications still cannot be delivered by postal mail under this system.
For example, both the Notice of Tax Audit Findings and the taxpayer’s responses must be submitted either electronically via Coretax, in person, or by fax. This shift aims to increase efficiency, reduce paperwork, and ensure a more traceable, accountable audit process.
Since the rollout of CoreTax, DGT has automated capabilities to identify discrepancies in real- time. For example:
- If a company files its corporate tax return (SPT 1771) showing a loss, but vendor- reported PPh 23 suggests significant income, the system may auto-generate an SP2DK.
- If an individual reports modest income but shows luxury spending (vehicles, overseas trips, property acquisitions), the system flags the case.
This modernization means taxpayers must maintain accurate, consistent, and well- documented reporting at all times.
3. Why These Changes Matter for Business
Following are the key changes in Indonesia tax audit procedures and their business impact.
These reforms require businesses to modernize workflows, maintain audit-ready documentation, and leverage digital systems for compliance.
The introduction of Minister of Finance Regulation No. 15 of 2025 brings not only procedural clarity but also tangible implications for companies operating in Indonesia. Businesses must now adapt to a faster, more structured, and more transparent tax audit process.
Previously, audits often lacked clear deadlines, which created uncertainty for companies. With fixed timeframes (5 months for comprehensive audits, 3 months for focused audits, and as short as 10 working days for specific audits), businesses can now better allocate resources, prepare documentation in advance, and plan for cash flow or potential adjustments with more certainty.
The requirement for a pre-audit meeting (Pembahasan Temuan Sementara) allows taxpayers to address discrepancies before the audit conclusion. This creates an opportunity to submit supporting evidence, correct misunderstandings, and reduce the risk of disputes escalating into penalties. Businesses that engage early in this process demonstrate transparency and strengthen trust with tax authorities.
With response times for audit findings shortened from seven to five working days, and no extensions permitted, companies must streamline their internal review processes. Tax, legal, and finance teams need to work in sync, ensuring that data validation and management sign- offs happen quickly to avoid missed deadlines that could trigger unfavorable outcomes.
The transition to a digital-first approach under the Core Tax Administration System means companies must be prepared to upload, sign, and manage documents electronically. Those without proper digital tax infrastructure may face compliance risks. This change also encourages businesses to adopt audit-ready digital archiving systems to ensure that all invoices, contracts, and supporting records can be retrieved immediately when requested.
Key Takeaway for Businesses
These reforms on the Indonesia tax audit procedure are not merely procedural—they represent a shift toward accountability, speed, and digital transparency. Companies that modernize their tax compliance workflows, invest in digital infrastructure, and maintain well-documented records will not only reduce risks but also benefit from quicker and more predictable audit outcomes.
4. How MAM Corporate Solutions Can Support You
MAM Corporate Solutions provides tailored audit readiness and compliance support— including:
- Pre-audit tax review based on the explanation request (SP2DK) from tax office. Learn more about SP2DK Tax Data Request here.
- Indonesia tax audit type assessment and readiness planning.
- Organizing supporting documents and digital submissions.
- Drafting effective responses to SPHP.
- Facilitating pre-audit discussions with tax authorities.
- Post-audit analysis and corrective recommendations.
Contact MAM Corporate Solutions today or fill in the form below for personalized consultation regarding Indonesia tax audit assistance and tax compliance services.
