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 2025

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

Indonesia updates double taxation avoidance regulations

Sponsored by

sponsored-firms-gnv.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

Identifying who will bear the costs and concerns around confidentiality are issues yet to be resolved, advisers say
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
AI will mean fewer entry-level roles in tax but also the emergence of new jobs, according to tax expert Isabella Barreto
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
Gift this article