#Tax Treaty

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

FAQ About The Advance Pricing Agreement

Here are some frequently asked questions regarding the Advance Pricing Agreement (APA) provision.

Mar 6, 2025

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

Through PP 55/2022, Advance Pricing Agreements Can Be Made Multilaterally

Application for Advance Pricing Agreements (APA) can now be made multilaterally. Thus, there are now three types of APA applications that apply in Indonesia. Previously, there were only two types of valid APA applications: bilateral APA application and unilateral APA application.

Feb 6, 2023

Purchase Tax on Software License, Royalty or Regular Buy and Sell?

In the context of taxes, software purchases often cause disputes. The purchase of software is different from the purchase of hardware, which is in the form of physical goods such as spare parts that must be imported from the producing countries.

Dec 15, 2022

Indonesia-Singapore Effectively Applied the New Tax Treaty on 1 January 2022

The revision of the Double Taxation Avoidance Agreement (P3B) or tax treaty between Indonesia and Singapore is officially effective as of 23 July 2021. As for the implementation of the updated tax treaty will be effectively carried out by each country per 1 January 2022. 

Aug 2, 2021

Minimizing Tax Treaty Abuse, Certificate of Domicile Review Procedure is Issued

To minimize the misuse of the double taxation avoidance agreement (P3B) facility or what is commonly called a tax treaty, the tax authority issues a review guideline on Certificate of Domicile (COD) documents.

Jun 8, 2021

Biden vs Trump and Its Effect on Indonesian Taxation

In the context of international relations between Indonesia and The US, there are always national interests that underlie the attitudes and positions of each country. So, whoever the future US president is—Biden or Trump—the direction of Indonesia’s tax policy will depend on Indonesia's attitude as a sovereign state.? 

Nov 9, 2020

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

Technical Guidelines for The Indonesia-Japan MLI Agreement Will Be Released Soon

Recently, the Japanese Ministry of Finance released a tax treaty document between Indonesia and Japan that has been modified in accordance with MLI. Regarding the matter, the government of Indonesia in this case the Directorate General of Taxes (DGT) said they would do the same by issuing a Circular Letter (SE) which will be a technical guide for the implementation of the agreement. 

Jun 19, 2020