DJP Issues Implementing Regulation on Global Minimum Tax

The Directorate General of Taxes (Direktorat Jenderal Pajak- “ DJP ”) will soon issue Regulation of the Director General of Taxes (“ Perdirjen ”) on administrative procedures and payment of the Global Minimum Tax (“ GMT ”), which is planned to take full effect in 2026. The Director General of Taxes, Bimo Wijayanto, stated that this instrument will accommodate the GMT payment mechanism, as currently regulated under Regulation of the Minister of Finance No. 136 of 2024 on Global Anti-Base Erosion Rules Based on International Agreements (“ Permenkeu 136/2024 ”).

“Currently, the drafting of the Perdirjen on GMT Administrative Procedures, as well as preparations for the Exchange of Information (“ EOI ”) between countries, is being finalized,” Bimo told Hukumonline.

The GMT scheme applicable in Indonesia involves the imposition of a top-up tax on Multinational Company (“ MNC ”) that have a minimum consolidated gross turnover of €750 million and do not pay taxes in the jurisdictions where they operate at a minimum rate of 15%.

The potential tax will be calculated under the Income Inclusion Rules (“ IIR ”). Alongside these provisions, there are also provisions on Undertaxed Payment Rules (“ UTPR ”) and the Domestic Minimum Top-up Tax (“ DMTT ”).