PMK 111/2025 on SP2DK Providing Legal Certainty in Tax Supervision
Minister of Finance Regulation (PMK) Number 111 of 2025 (PMK 111/2025) provides a stronger legal basis for the Letter of Request for Explanation of Data and/or Information (Surat Permintaan Penjelasan atas Data dan/atau Keterangan/SP2DK) as an instrument for tax compliance supervision by the Directorate General of Taxes (DGT). The regulation governs the function, basis for issuance, taxpayers’ rights, and follow-up mechanisms of SP2DK.
Provisions on SP2DK now rest on a more solid legal framework after the issuance of PMK 111/2025.
Previously, SP2DK was only regulated under DGT Circular Number SE-05/PJ/2022 (SE-05/PJ/2022). Under the new regulation, SP2DK is part of the DGT’s internal business process for tax compliance supervision.
In other words, the earlier rules on SP2DK applied only internally as guidance for Account Representatives (ARs). However, as a circular letter, SE-05/PJ/2022 had limited legal force.
Regulated under PMK 111/2025, SP2DK now assumes a more formal role as a supervisory instrument within Indonesia’s self-assessment system. This means that SP2DK is no longer merely a normative supervisory tool used by tax auditors.
Function of SP2DK in Tax Compliance Supervision
Under SE-05/PJ/2022, SP2DK served as a means to request explanations of data and/or information as a result of material compliance analysis. Its function was integrated into a supervisory process that could lead to various administrative follow-up actions.
PMK 111/2025 reaffirms SP2DK as an instrument for requesting explanations of data and/or information for compliance supervision. This regulation explicitly distinguishes SP2DK from tax audits and preliminary evidence examinations. SP2DK is placed at the initial stage of administrative supervision.
Basis for Issuing SP2DK
According to SE-05/PJ/2022, SP2DK was issued based on the results of data and information analysis available in the DGT’s supervisory system, including material compliance reviews conducted by ARs.
Meanwhile, PMK 111/2025 reaffirms that SP2DK is issued based on research into data and/or information owned or obtained by the DGT. Such data are integrated within the tax administration system, providing a formal basis for supervisory actions through SP2DK.
Applicable to Any Person
Through PMK 111/2025, the government expands the scope of tax supervision beyond registered taxpayers to include parties who have not yet registered as taxpayers.
This means that the DGT may issue an SP2DK to any person based on information available in its system. The scope of supervision covers Income Tax (PPh), Value Added Tax (PPN), Sales Tax on Luxury Goods (PPnBM), Stamp Duty, Land and Building Tax (PBB) for certain sectors, Carbon Tax, and other types of taxes.
In general, parties subject to DGT supervision include:
- Registered taxpayers
- Unregistered taxpayers
- Area-based supervision
- Taxpayers’ rights and obligations under SP2DK
Under SE-05/PJ/2022, taxpayers’ rights and obligations in responding to an SP2DK were regulated as part of internal supervisory procedures. The provisions included the obligation to provide explanations and the right to clarify the requested data.
PMK 111/2025 explicitly regulates these rights and obligations at the ministerial regulation level. Taxpayers are granted the opportunity to submit explanations and supporting evidence within a specified timeframe according to applicable provisions.
Response and Discussion Mechanism
SE-05/PJ/2022 governed SP2DK response mechanisms, including the submission of explanations in writing, verbally, or through electronic media, as well as the conduct of discussions and preparation of official reports as part of the supervisory process.
PMK 111/2025 adopts and formalizes these mechanisms, including provisions on response deadlines, discussion procedures, and documentation of supervisory results. These mechanisms are now part of the generally applicable supervision procedures.
Follow-Up Actions on SP2DK
Under SE-05/PJ/2022, SP2DK process results may be followed up through various administrative actions, such as closing the supervision process, ex officio data adjustments, proposals for tax audits, or other follow-up actions based on supervisory analysis.
PMK 111/2025 formulates SP2DK follow-up actions more clearly, including the closure of supervision, data adjustments, confirmation or revocation of VAT-Registered Person (PKP) status, and proposals for tax audits or preliminary evidence examinations according to prevailing laws and regulations.
Reframing Tax Supervision under PMK 111/2025
Overall, PMK 111/2025 restructures the regulation of SP2DK previously governed under SE-05/PJ/2022. While the technical substance of SP2DK remains unchanged, its regulation is now placed within a broader regulatory framework, supported by a more systematic supervisory framework and a higher legal standing. (ASP/ASA)
