Indonesia updates double taxation avoidance regulations

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Indonesia updates double taxation avoidance regulations

Sponsored by

GNV Green BG.png
AdobeStock_133597471_pots

Indonesia's Director General of Tax (DGT) issued Regulation No. PER-25/PJ/2018 (PER-25) on November 21 2018, simplifying the procedures concerning the implementation of the double taxation avoidance agreement.

PER-25 replaces previous Regulation No. PER – 10/PJ/2017.

PER-25 introduces a template and procedures related to the certificate of domicile (DGT form). It can be summarised as follows:

  • It must be submitted once within the period covered by the DGT form (no longer per month);

  • The DGT form is prepared by the offshore tax resident and submitted online by the Indonesian tax withholder, with receipt. The DGT form reporting receipt should be provided to the offshore tax resident;

  • The offshore tax resident will only be required to provide the receipt for the future transaction covered under the DGT form period to the Indonesian tax withholder;

  • The period covered is a maximum of 12 months, and may extend over the calendar year (e.g. August 2018 – July 2019).

  • The DGT form should be reported no later than the deadline of submitting the withholding tax (WHT) return for the period where the withholding is payable (which is normally on the 20th of the following payable period). For example, for a payable period of January 2019, the DGT form should be reported no later than the deadline of submitting the January 2019 WHT return (i.e. February 20 2019);

  • The Indonesian tax withholder is required to check the DGT form receipt provided by the offshore tax resident to the online system for its validity; and

  • Failure to provide a valid DGT form on time and fulfill the no tax treaty abuse condition will result in the Indonesian tax withholder having to withhold the tax using a normal tariff of 20%, instead of the tax treaty tariff which is normally lower than 20% (or even 0%).

PER-25 is effective from January 1 2019.

more across site & shared bottom lb ros

More from across our site

While the IBS incorporates taxable events previously covered by state and municipal taxes, its governance and operational logic represent a significant departure from the legacy model
The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole
Almost three-quarters of surveyed tax professionals are concerned about inaccurate AI outputs; in other news, Dentons hired a partner from CMS to lead its Belgian tax team
Long-running, high-value and complex enquiries are a significant reason for HM Revenue and Customs’s increased TP yield, experts suggest
Landmark legal updates in India have led companies to prioritise specialised tax advisers over accountants, ITR has found
Brazil’s shift to a nationwide consumption tax is more than conceptual; it fundamentally transforms municipal revenue, enforcement, and administrative disputes
While some advisers praised the ruling’s definition of a ‘voucher’ for VAT purposes, a UK partner said the case left unanswered questions
While pillar two has been enacted on paper in Brazil, companies are encountering a range of practical compliance issues, ITR has heard
Gift this article