DGT Issues New Regulation on Registered Taxpayer Location

The Directorate General of Taxes (DGT) has issued a new regulation concerning the determination of the registered location of individual and corporate taxpayers at Large Tax Offices, Special Tax Offices, and Intermediate Tax Offices.

The new provisions are outlined in the Director General of Taxes Regulation Number PER-17/PJ/2025, which simultaneously revokes two previous regulations on the same matter, namely PER-07/PJ/2020, as amended by PER-05/PJ/2021.

In its considerations, the DGT stated that the regulatory update was carried out to ensure alignment with the Coretax system, as regulated under Minister of Finance Regulation (PMK) Number 81 of 2024.

In general, this new regulation focuses more specifically on the designation of the registered location for individual and corporate taxpayers. In contrast, the previous regulations had broader coverage, as they also detailed the implementation of taxpayers' rights and obligations.

Criteria for Taxpayers and Their Registered Location

The Directorate General of Taxes (DGT) may determine the registered location for certain taxpayers—individuals or entities—who do not meet the subjective criteria as domestic tax subjects or income tax subjects, based on the following criteria:

• Business revenue
• Amount of income
• Amount of tax payments
• Asset value
• Liabilities and equity
• Place of domicile and/or place of business activity
• Nationality
• Business classification 
• Taxpayer group or beneficial owner
• Other considerations by the Director General of Taxes

These criteria serve as the basis for assigning a taxpayer to a particular Tax Office (KPP) under the new regulatory framework.

Types of Tax Offices (KPP)

Each taxpayer will be assigned to a Tax Office (KPP) based on the criteria mentioned earlier (e.g., business turnover, income, nationality, etc.). There are three main types of KPPs:

1. Large Tax Offices (KPP Wajib Pajak Besar)

Tax Offices	Description
Large Tax Office 1	For certain large corporate taxpayers in the mining, mining support services, and financial services sectors.
Large Tax Office 2	For certain large corporate taxpayers in industry, trade, and services (excluding mining support and financial services).
Large Tax Office 3	For State-Owned Enterprises (BUMN) operating in the mining, industry, and trade sectors
Large Tax Office 4	For State-Owned Enterprises in the service sector and certain individual taxpayers.

These offices are designated for large corporate taxpayers and specific high-profile individuals. There are four main Large Tax Offices:

2. Jakarta Special Tax Offices (KPP Jakarta Khusus)

These offices handle foreign investment (PMA) taxpayers, listed companies, foreign entities or individuals, and oil and gas taxpayers. Details:

1. KPP PMA 1, for certain non-listed foreign investment companies in the chemical industry and non-metal mineral products sector..
2. KPP PMA 2, for certain non-listed PMAs in the metal and machinery industry.
3. KPP PMA 3, for certain non-listed PMAs in mining and trade.
4. KPP PMA 4, for certain non-listed PMAs in textiles, food, and wood industries.
5. KPP PMA 5, for certain non-listed PMAs in agribusiness and specific services.
6. KPP PMA 6, for certain non-listed PMAs in services and specific trade sectors.
7. KPP for Listed Companies: For companies whose initial public offering (IPO) has been declared effective by the capital market authority, non-bank securities companies, and self-regulatory organizations (SROs) operating under the Capital Market Law.
8. KPP for Foreign Individuals and Corporate: For individuals or entities that do not meet the subjective criteria as domestic tax subjects, including e-commerce (PMSE) businesses, and foreign taxpayers not covered under Article 3 of the Income Tax Law (UU PPh).
9. KPP for Oil and Gas: Specifically for oil and gas taxpayers.

 

3. Intermediate Tax Offices (KPP Madya)

These offices are designated for specific taxpayers within a regional tax office jurisdiction. Typically, these include medium-to-large businesses that are not assigned to Large or Special Tax Offices.

This structured assignment is part of the effort to align taxpayer registration with the Coretax system and streamline tax administration based on taxpayer characteristics.

Determination of Registered Taxpayer Location

The Directorate General of Taxes (DGT) assigns individual or corporate taxpayers to specific Tax Offices (KPPs) according to established criteria by issuing a Decree of the Director General of Taxes, except for foreign PMSE (Trade Through Electronic System) operators that have already been appointed as VAT collectors.

Meanwhile, for individual and corporate taxpayers who already meet the criteria but have not yet been assigned to a specifictax offices, they may register voluntarily (self-assessment) at the Pratama Tax Office located within their domicile or operational area.

However, the following taxpayers are excluded from registering at Pratama Tax Office:

• Oil and gas taxpayers must register at the Oil and Gas Tax Office
• International organizations must register at the Foreign Individuals and Corporate Tax Office (KPP Badan dan Orang Asing)
• Individuals or entities that are not domestic tax subjects, such as foreign traders, foreign service providers, and PMSE operators, must also register at the Foreign Individuals and Corporate Tax Office 
• Representatives of foreign countries, their officials, as well as international organizations and their officials, are required to register at the Foreign Individuals and Corporate Tax Office

Once a decree (decision letter) has been issued, the taxpayer’s tax rights and obligations must be carried out using their Taxpayer Identification Number (TIN) as registered at the designated KPP.

Place of VAT-Registered Person (PKP) Confirmation

The tax office where the taxpayer is registered also serves as the place for reporting the business to be confirmed as a VAT-registered person.

Confirmation as a PKP is required if the taxpayer is a business operator obliged to be confirmed as a VAT-Registered Person, or a business operator who chooses voluntarily to be confirmed as a VAT-Registered Person. (ASP/KEN)