Discussion of Interim Findings, a Crucial Dialogue Space in Tax Audits

Tax audits are often a stressful process for taxpayers. In practice, many companies feel they are in a passive position throughout this process.

The tax auditor presents findings, the taxpayer listens, and then either accepts or contests them after the Issuance of the Notification of Tax Audit Findings (SPHP). However, this approach is now shifting toward a more participatory model.

Amid ongoing efforts to reform the tax system, the issuance of Minister of Finance Regulation (PMK) Number 15 of 2025 on Tax Audits introduces several significant changes.

READ: Government Updates Regulation on Tax Audit Procedures

One provision that deserves special attention is the regulation of the obligation to discuss interim findings before the tax auditor issues the Notification of Tax Audit Findings (SPHP).

To some, the discussion of interim findings may sound like a routine administrative step. In reality, however, it is one of the most strategic and critical points in the entire tax audit process, a stage where the outcome of a company’s fiscal adjustments can change significantly, depending on how well the taxpayer prepares and utilizes the available space for dialogue.

Unfortunately, many taxpayers have yet to recognize the importance of this stage. In fact, the discussion of interim findings is a formal forum that allows the auditor and the taxpayer to sit down together, engage in open dialogue, and present their arguments before the audit conclusions are finalized in the Notification of Tax Audit Findings.

READ: Taxpayers Can Do The Voluntary Disclosure of Tax Returns Before SPHP is Issued

From Partial Initiative to Formal Obligation

Before the enactment of PMK 15/2025, some tax auditors did take the initiative to proactively share a draft of the audit findings in advance with the taxpayer. This practice helped facilitate communication and provided an opportunity for clarification before the Notification of Tax Audit Findings (SPHP) was issued. However, such practices were not uniform and largely depended on each auditor’s individual approach.

Now, with the issuance of PMK 15/2025, the government has clearly declared that the discussion of interim findings is a mandatory part of the tax audit procedure. Auditors are no longer permitted to proceed directly to the SPHP without first presenting the interim findings to the taxpayer and formally discussing them in a written official record (berita acara).

This measure aligns with the principles of accountability and fairness within the tax system. Auditors are required to present the basis for their corrections transparently, while taxpayers are granted the opportunity to respond with evidence-based and well-reasoned arguments. As a result, audit outcomes are expected to be more objective, proportionate, and free from factual errors that could otherwise lead to potential disputes in the future.

Requiring Taxpayer Readiness

Although now mandated by regulation, the process of discussing interim findings demands both preparation and commitment from the taxpayer. This ensures that the dialogue with the auditor is used as effectively as possible.

Once the Notification of Tax Audit Findings (SPHP) is issued, the opportunity for open discussion narrows significantly. Any objections or disagreements can only be raised through subsequent formal procedures, which often require more time and, in many cases, lead to tax disputes that incur higher costs.

On the other hand, if the taxpayer makes the most of this moment by preparing supporting documents, constructing sound fiscal arguments, and presenting a comprehensive financial narrative, many proposed adjustments can be revised or even eliminated before the SPHP is issued.

READ: MUC BIJAK Webinar: Strategies for Facing Tax Audits in the Coretax Era

Strategies for Responding to the Discussion of Interim Findings

As a tax professional, I encourage companies and business actors to approach this stage proactively and strategically. Several key actions to consider include:

1. Understand the Structure and Chronology of the Audit Process

Do not wait until you are summoned for the discussion. From the very beginning of the audit, ensure your internal team understands the company’s fiscal position and potential areas subject to adjustment.

2. Prepare Supporting Documentation from the Outset

Well-organized and relevant documentation is crucial. When the auditor presents interim findings, the taxpayer must be ready to respond with evidence—not merely with opinions or assumptions.

3. Conduct a Critical Analysis of the Auditor’s Findings

Not all adjustments are absolute. Differences in interpretation or misunderstandings can occur. This is where critical analysis and constructive communication become essential.

4. Involve a Professional if Needed

If your internal team lacks sufficient capacity, do not hesitate to involve a tax consultant. The right guidance can be immensely valuable in formulating strong and persuasive fiscal arguments.

Taxpayer Rights and Auditor Obligations

In conclusion, it can be summarized that PMK 15/2025 delivers two key messages. First, the discussion of interim findings is now a guaranteed right for every taxpayer. Second, tax auditors are obligated to provide this space for dialogue before finalizing the audit results.

Tax reform is not solely about digitalization through Coretax or strengthening data infrastructure. True reform also addresses the relational dimension—how communication between the tax authority and taxpayers is built in a healthy, transparent, and fair manner.

And this is precisely where the discussion of interim findings plays a vital role. It is a golden opportunity that should not be overlooked. Therefore, let us shift our mindset: from passive and reactive to active, prepared, and engaged from the outset.

When the state facilitates a space for dialogue, what we must do is show up, understand, and speak up. (ASP/KEN)

Disclaimer! This article is a personal opinion and does not reflect the policies of the institution where the author works.