Understand the Risks of Using a Temporary Tax ID Number (TIN) in Withholding Income Tax Slips

For employers and companies, accuracy in preparing withholding income tax slips is not merely an administrative matter but also concerns credibility and compliance.
When preparing a withholding slip, taxpayers must include the recipient’s Tax ID Number (TIN), which has already been matched with the National Identification Number (NIK).
However, if the income recipient has not completed the TIN-NIK matching, the withholding slip may be issued using a temporary Tax ID Number (TIN).
For reference, a withholding income tax slip is a form or other equivalent document prepared by the withholding agent. Its function is to serve as proof of withholding income tax carried out by the withholding agent.
Withholding is conducted by the party providing income to a resident individual taxpayer, in connection with employment or other activities performed.
Not Automatically Delivered
To obtain a temporary TIN, taxpayers may access the Coretax system. However, the use of a temporary TIN carries risks that must be considered.
The Directorate General of Taxes (DGT) stated in a written announcement that withholding slips issued using a temporary TIN will not be delivered to the recipient.
As a result, the withholding slip will not appear or be prepopulated in the recipient’s annual income tax return (SPT), and the withheld tax cannot be credited.
Therefore, even though the tax authority provides this facility, taxpayers are encouraged to complete the TIN-NIK matching.
Withholding Slip Preparation Schemes
The preparation of withholding slips in the Coretax system can be done under three schemes. First, by manually inputting each withholding slip in Coretax.
Second, by using an *.XML file in the taxpayer account of the income provider for a large number of recipients. Third, through an authorized tax application service provider.
Types of Withholding Income Tax Slip Forms
According to Regulation of the Director General of Taxes No. PER-11/PJ/2025, there are several types of withholding slip forms depending on the type of withholding income tax:
1. Form BPA1
Used for withholding Income Tax Article 21 on permanent employees or retirees receiving periodic pension payments.
2. Form BPA2
Used for withholding Income Tax Article 21 on Civil Servants (PNS), members of the Indonesian National Armed Forces (TNI), or the Indonesian National Police (Polri).
3. Form BP21
Used for withholding Income Tax Article 21, which is non-final and final.
4. Form BP26
Used for withholding Income Tax Article 26 (withholding slip for Income Tax Article 26).
Correction of Tax Withholding Slips
If errors occur in filling out Withholding Income Tax Article 21 or Withholding Income Tax Article 26 slips, taxpayers may make corrections. Certain requirements must be met to do so.
First, no audit or preliminary audit of the Withholding Income Tax Article 21/26 return (SPT Masa) has been conducted. Second, the withholding slip has not been submitted for objection.
Third, the withholding slip was submitted for objection but not considered. Fourth, it was submitted for objection but later withdrawn by the DGT upon the taxpayer’s request. (ASP/KEN)