Tax Audit Procedure in Indonesia: Types, Deadlines and Rights

Indonesia’s tax audit procedure is set by PMK No. 15 of 2025, the Minister of Finance regulation on tax audits (pemeriksaan pajak), in force since 14 February 2025. It sorts every compliance audit into one of three types and gives each a fixed time limit.

It also sets short deadlines for the taxpayer at the points that decide the outcome. An audit that began before 14 February 2025 finishes under the old rules (Article 30).

An audit can be opened for any of fourteen reasons, among them a refund request, a return showing an overpayment or a loss, selection on risk, and concrete data showing tax unpaid (Article 4(1)). It can also follow an SP2DK, the tax office’s request for an explanation, where the answer did not settle the question.

Three audit types, three time limits

The old distinction between a field audit and an office audit has gone. Where an audit happens — the tax office, the taxpayer’s premises, or elsewhere — is now left to the auditor (Article 5(4)(d)). What distinguishes the types is how much of a return is examined.

Testing runs from the day the audit notice is delivered to the day the notice of audit findings is delivered; the closing period runs from there to the date of the audit report (Article 6(2)–(3)). A focused audit’s items must be named to the taxpayer in writing (Article 10(4)).

Concrete data is narrow: an approved VAT invoice the taxpayer has not reported, a withholding slip its issuer has not reported, or transaction evidence from which the tax can be calculated (Article 4(2)).

For a taxpayer in a group, or one showing signs of transfer-pricing or other engineered transactions, testing can be extended by up to four months on top of the periods above, and the taxpayer must be told (Article 6(5)–(7)).

From audit notice to assessment

1. 1
   Day 0

   The audit notice is delivered

   The audit starts on that date (Article 10(6)). The auditor explains its reasons and your rights at an opening meeting, or in writing for a specific audit (Article 11). From now on no amended return can be filed for what is being audited (Article 10(7)).

2. 2
   1 month per request

   Records and documents are requested

   Each request letter must be met within one month of delivery, with written reminders at two and three weeks (Article 12(2) and (5)).

3. 3
   At least 1 month before testing ends

   The temporary findings are discussed

   You see the provisional findings and can answer them with records, witnesses or experts. Comprehensive and focused audits only (Articles 7(3) and 17).

4. 4
   End of testing

   Notice of audit findings (SPHP)

   The auditor's findings and proposed corrections, delivered electronically, in person or by fax — not by post (Article 27(2)).

5. 5
   5 working days from receipt

   Your written response

   In writing, agreeing, agreeing in part or disagreeing (Articles 18(2) and 20(7)). The regulation provides no extension.

6. 6
   Invited within 3 working days

   The closing conference

   The findings are discussed and minutes are signed recording the corrections and any disagreement (Article 18(4)–(9)).

7. 7
   Request within 3 working days

   The Quality Assurance team, if asked for

   Where a disagreement is only about the legal basis of a correction, you may ask for it to go to this panel, whose decision binds both sides (Article 19).

8. 8
   Result

   Audit report and tax assessment

   The report is the basis for the tax assessment letter (SKP), showing tax underpaid, overpaid or nil (Article 20(3)).

The response window was seven working days, with three more available on notice, under the rules PMK 15/2025 replaced (PMK 17/2013, Article 42(2)–(3)). Five working days, with no extension, is the tightest deadline in the process.

Documents: the rule that follows you to objection

Records handed over after the one-month window are treated as not provided (Article 12(4)). That is not new — the tax procedures law has required it since 2007 (UU KUP, Article 29(3a)) — but its effect reaches beyond the audit. Records not given during an audit are not considered in an objection (UU KUP, Article 26A(4)).

Two kinds of document may still be handed in up to the signing of the closing-conference minutes (Article 12(11)–(12)):

• requested documents the taxpayer has not yet obtained from a third party
• the taxpayer’s own documents other than those requested

A taxpayer who spots its own error during an audit cannot amend the return, but can disclose that the return was incorrect and pay the shortfall with interest, until the notice of findings is delivered (Article 22; UU KUP, Article 8(4)). The audit carries on.

A taxpayer who refuses an audit must sign a statement saying so within seven days of the notice. The auditor may then assess the tax on their own calculation, or propose a preliminary criminal investigation (Article 15). Refusing an audit on purpose, where it can cost the state revenue, is also an offence under UU KUP Article 39(1).

After the assessment: objection and appeal

An objection is filed in writing, in Indonesian, with the taxpayer’s own figure and the reasons for it (UU KUP, Article 25(2)–(3)). Before filing, pay at least the tax agreed at the closing conference (Article 25(3a)); an objection that misses any of these requirements is not treated as an objection at all (Article 25(4)). The disputed balance is not due until a month after the decision (Article 25(7)).

The Directorate General has 12 months to decide, and if it does not, the objection is granted (Article 26(1) and (5)). The decision can also increase the tax (Article 26(3)). An appeal goes only to the Tax Court (Article 27(1) and (3)). The fines were 50% and 100% before UU No. 7 of 2021 reduced them (Articles 25(9) and 27(5d)).

What this means for you

Most of an audit’s outcome is settled before the closing conference. Answer every request letter inside its month, attend the findings discussion with the records that answer it, and treat the five working days for the response as the deadline that matters most. A company whose corporate tax files reconcile to its ledgers answers most requests from records it already has, and the same holds for an individual’s personal tax return.