#Double Tax Avoidance

PMK 112/2025 Strengthens DGT Authority Over Test Avoidance of Permanent Establishment Status Related to Tax Treaty 

Jan 22, 2026

Beneficial Owner Status As an Indicator of Tax Treaty Misuse by Non-Resident Taxpayers

Beneficial owner status is no longer merely a formal requirement in the DGT Form. Take a look at PMK 112/2025, indicators of treaty abuse, and examples of treaty shopping cases. 

Jan 21, 2026

Understanding the Principal Purpose Test, Rules on Anti-Abuse of Tax Treaty in PMK 112/2025

Understanding the Principal Purpose Test (PPT) in PMK 112/2025 as an Anti-Tax Treaty Abuse Regulation, including case studies, interpretational challenges, and mitigation strategies for taxpayers.

Jan 15, 2026

Government Issues More Detailed Tax Treaty Provisions under PMK No. 112 of 2025

The Minister of Finance Regulation (PMK) No. 112 of 2025 sets out the latest provisions on the implementation of Tax Treaties (P3B), covering Certificates of Domicile for Domestic Taxpayers (SKD WPDN), DGT Form for Foreign Taxpayers (WPLN), as well as the evaluation of beneficial ownership.

Jan 7, 2026

Ratification Regulation on the Convention of Tax Collection Assistance to be Revised

The government will revise the provisions regarding the ratification of the Conventional on Multilateral Administrative Assistance in Tax Matter, namely Presidential Regulation (Perpres) Number 159 of 2014.

Feb 28, 2024

Tax Treaty Provisions for Coldplay Concert Income in Indonesia

Concert activities of foreign musicians, such as Coldplay in Indonesia, are bound by tax provisions stipulated in the Double Tax Avoidance Agreement (DTA) or tax treaty.

Nov 22, 2023

Preventing Tax Avoidance, PP 55/2022 Adopts New Borrowing Cost Provisions

This method will compare earnings before deducting interest, taxes, depreciation and amortization (EBITDA) or Earning Stripping Rules (ESR).  This method is also known by other terms, such as Fixed Ratio, Interest-to-Profits Ratio.

Feb 1, 2023

The Mutual Agreement Procedure Breaks the Deadlock of Double Taxation Disputes

Domestic taxpayers can apply for MAP to the Directorate General of Taxes (DGT) or the tax authorities of the DTA partner countries if they feel getting improper tax treatment from each authority or even both. 

Oct 13, 2020

Latest Data Released, OECD Highlights Multinational Company Profit Shifting

OECD released the latest data on corporate tax "Corporate Tax Statistics" on 8 July, 2020. The data contains aggregate and anonymous statistics from data collected under BEPS Action 13 Country-by-Country Reports (CbCR). Based on the data, there are indications of the efforts of multinational companies in making profit shifting.

Jul 10, 2020

Indonesia in Welcoming the Era of Open Information on Taxation

Automatic Exchange of Information (AEoI) has become the commitment of the world’s leaders to stop the acts of tax avoidance and track the actors’ financial transactions.

Mar 3, 2017