New DJP Rule: Tax Arrears Now a Requirement for Approval of Mining Business Plans

The Directorate General of Tax (“DJP”) of the Ministry of Finance (“Kemenkeu”) is accelerating the drafting of Draft Regulation of the Minister of Finance (“Draft Regulation”) on Tax Regulations in the Mineral and Coal Mining Business (“Minerba”). The government has stipulated that compliance with the settlement of tax arrears is an absolute requirement for the approval of the Minerba Work Plan and Budget (“RKAB”) for holders of Mining Business License (“IUP”) and Special Mining Business License (“IUPK”), as stipulated in the provisions on supervision of taxpayer compliance in Regulation of the Minister of Finance No. 111 of 2025. 

“Internal discussions are currently underway to include a commitment to settle tax arrears as one of the required supporting documents when submitting the RKAB,” an internal source from the DJP at the Ministry of Finance told Hukumonline.

This Draft Regulation is projected to overhaul corporate tax compliance management, ranging from procedures for calculating Corporate Income Tax (“PPh”), certainty on royalty schemes, to the administration of Land and Building Tax (“PBB”) in the Minerba sector. Furthermore, non-compliance or the existence of unresolved tax arrears not only risks triggering tax disputes but also has direct implications for the suspension of mining operational permits due to the withholding of RKAB approval.