DGT Issues Regulation on Tax Compliance Testing Based on Concrete Data

The Directorate General of Taxes (DGT) has issued a new regulation for testing taxpayer compliance based on concrete data obtained by the DGT.

The regulation is the Director General of Taxes Regulation Number PER-18/PJ/2025 concerning the follow-up on concrete data, which was issued and came into effect on September 24, 2025.

For reference, this regulation is a derivative of Law Number 6 of 1983 on General Provisions and Tax Procedures, as amended by Law Number 6 of 2023 on Job Creation.

In addition, this regulation also serves as a follow-up to Minister of Finance Regulation (PMK) Number 15 of 2025 on Tax Audit.

Types of Concrete Data

The term concrete data refers to data obtained by the Directorate General of Taxes (DGT) that still requires simple verification. Examples of concrete data include:

Tax Invoices

Tax invoices that may be considered as concrete data are those that have been approved through DGT's information system but have not been, or were not, reported by the Taxpayer in their Value Added Tax (VAT) Periodic Tax Return.

Income Tax Withholding/Collection Slips

Withholding or collection slips for Income Tax that may be used as concrete data are those that have not been, or were not, reported by the issuer in their Income Tax Periodic Tax Return.

Transaction Evidence or Tax Data

Transaction evidence or tax-related data may be treated as concrete data to be followed up on if it can be used to calculate the taxpayer’s tax obligations. This includes:

• Excess credit claimed in a VAT return that is not supported by excess payments in the previous VAT return.
• Recalculation of input tax used to offset output tax by a VAT-registered person (PKP) who is not entitled to apply input tax crediting guidelines for supplies that are both subject to and not subject to VAT.
• Prepaid VAT that is underpaid or not paid.
• Misuse of tax incentives in violation of applicable regulations.
• Improper input tax crediting.
• Income not reported or underreported based on withholding slips held by the DGT and/or errors related to the use of deemed profit norms (norma penghitungan penghasilan neto).
• Data or information sourced from tax assessments, decisions in the field of taxation, or final and binding rulings on tax disputes that can be directly used to calculate tax obligations that were not reported or underreported in the Tax Return.
• Data or information for which:

1. A request for explanation has been issued, and
2. A record of explanation has been prepared containing the Taxpayer’s agreement to fulfill their tax obligations, signed by the Taxpayer or their representative or proxy, but the obligations were not fulfilled by the agreed deadline.

Follow-Up on Concrete Data

There are two follow-up options that the Directorate General of Taxes (DGT) may take regarding concrete data: through supervision or through audit.

If the follow-up is conducted in the form of an audit, it will be carried out as a specific audit. (ASP/KEN)