DGT Consolidates Rules on Exchange of Information for Taxation

The Directorate General of Taxes (DGT) has issued a new regulation regarding the exchange of information for taxation purposes, namely Director General of Taxes Regulation Number PER-10/PJ/2025.

This regulation consolidates several previous rules concerning information exchange, covering exchange of information upon request, spontaneous exchange, and automatic exchange.

The regulation, which was issued and came into effect on May 22, 2025, also governs competent authority meetings, tax examinations abroad, and simultaneous tax examinations as part of the information exchange implementation.

With the enactment of this regulation, the previous regulations related to information exchange have been officially revoked. These include: First, PER-67/PJ/2009 on procedures for exchanging information under double taxation agreements.

Second, PER-28/PJ/2017 on procedures for exchanging information upon request within the framework of international agreements. Third, PER-24/PJ/2018 on procedures for spontaneous information exchange. Fourth, PER-02/PJ/2022 on the implementation of competent authority meetings, tax examinations abroad, and simultaneous tax examinations.

Definition of Exchange of Information

Exchange of information upon request is carried out based on a request from the competent authority in Indonesia to the competent authority in the partner country/jurisdiction, or vice versa, concerning information on tax matters.

Meanwhile, spontaneous exchange of information is conducted by the competent authority in Indonesia by providing information deemed relevant for taxation purposes to the tax authority of the partner country/jurisdiction, or vice versa, spontaneously or without a prior request.

Lastly, automatic exchange of information is conducted by the competent authority at specific times, on a periodic, systematic, and ongoing basis, regarding matters related to taxation.

Implementation of the Exchange of Information

The exchange of information conducted by the Director General of Taxes includes data requests, spontaneous exchanges, automatic exchanges, and forms of investigative cooperation.

1. Types of Information Exchanged

In the case of exchange upon request, the information may include identity and ownership data, accounting information, banking information, tax information, and/or other relevant information.

For spontaneous exchange, the information may relate to transactions or activities between Indonesian taxpayers and taxpayers from partner jurisdictions, information on domestic tax regulations, and/or other information deemed useful for each country/jurisdiction.

In the case of automatic exchange, the information may include details on tax withholdings, such as income tax (PPh) withheld and paid by partner country taxpayers or Indonesian taxpayers. It may also include other information relevant for taxation purposes.

2. Mechanism of Information Exchange

The exchange of information can be conducted on a reciprocal basis through Competent Authority Meetings, Tax Examinations Abroad, and/or Simultaneous Tax Examinations.

Competent Authority Meetings

Competent Authority Meetings are meetings between competent authorities to discuss matters related to information exchange. These meetings may be initiated by the Director General of Taxes or by the competent authority of a partner country/jurisdiction. The meetings can be held in person or through indirect means such as phone calls, video conferences, or other mutually agreed-upon methods.

Tax Examinations Abroad

Tax Examinations Abroad involve the search and collection of information by sending DGT representatives to the partner country/jurisdiction. This is done for tax audits or other activities carried out by the tax authorities of the partner country or vice versa, based on mutual agreement.

There are two types of Tax Examinations Abroad: Tax Examinations Abroad are conducted abroad, and Tax Examinations Abroad are conducted domestically.

• Tax Examinations Abroad conducted abroad are carried out when a taxpayer is under audit, a preliminary evidence examination is in progress, or a criminal tax investigation is being conducted with significant tax revenue potential.
• Tax Examinations Abroad conducted domestically are carried out when they contribute significantly to the resolution of a tax case.

There are several prerequisites for conducting Tax Examinations Abroad. First, an exchange of information upon request has been carried out, but the information received is insufficient. Second, an exchange of information upon request is in progress, but there is a need to expedite the acquisition of information. Third, follow-up is required on a spontaneous request.

Simultaneous Tax Examinations

Simultaneous Tax Examinations refer to the activity of searching for and collecting information through tax audits conducted in Indonesia and in one or more partner countries/jurisdictions, simultaneously and independently. This activity is carried out based on mutual agreement and aims to exchange relevant information obtained from the respective examinations.

There are two types of Simultaneous Tax Examinations:

• Simultaneous Tax Examinations initiated at the request of the Director General of Taxes, and
• Simultaneous Tax Examinations initiated at the request of an official from a partner country/jurisdiction.

Processing and Use of Exchanged Information

All exchanged information is confidential. Therefore, every unit head within the Directorate General of Taxes (DGT) who receives exchanged information must follow up on each piece of information in accordance with established procedures for securing, maintaining confidentiality, storing, reporting, and supervising the storage of such information.

Furthermore, the information may only be used in line with DGT’s main duties and functions. This includes cases where the information is used to issue a tax assessment letter, or even if the information is received after a tax assessment letter or a final and binding court decision has been issued.

In carrying out the exchange of information, the Director General of Taxes may delegate authority to the Director of International Taxation or to an Echelon II official within DGT. (ASP/KEN)