Indonesia has implemented the global minimum tax. Minister of Finance Regulation No. 136 of 2024 took effect on 1 January 2025 and adopts the OECD/G20 GloBE Rules into Indonesian law. Groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding financial years are within scope, and for those groups FY2025 was the first year of application. 

What was previously missing were the administrative procedures. DGT Regulation No. PER-6/PJ/2026 has now set out how in-scope groups register, what they file, and when payment falls due. The obligations arising from FY2025 therefore have fixed dates, the first of which is 30 September 2026. 

The Important Dates 

Registration is the first obligation. An in-scope group must apply to be registered as a GloBE taxpayer within nine months of the end of its first application year, which is 30 September 2026 for a group with a December year-end. 

Top-up tax must be paid by 31 December 2026, before the return is filed. Payment therefore precedes filing, and the amount remitted in December will be based on the computation available at that time. 

The returns are due four months after the GloBE tax year ends, with an extension of up to two months available in the first year. PER-6 provides for three separate returns: a GloBE annual income tax return, a DMTT annual income tax return for each constituent entity, and a UTPR annual income tax return where top-up tax has been allocated to Indonesia. The GloBE Information Return, in OECD XML format, is due on 30 June 2027, eighteen months after the end of the transition year. For subsequent years the period is fifteen months. 

Who files the GloBE Information Return 

In most groups the ultimate parent entity files the GloBE Information Return (GIR) in its own jurisdiction, or the group appoints a designated filing entity to do so. Where that occurs, Indonesian constituent entities are not required to file. 

The exemption is conditional. It applies only where the return is filed in a jurisdiction that has a qualifying competent authority agreement (QCAA) in force with Indonesia for the exchange of that return. The relevant question is whether Indonesia will receive the return, not whether it has been filed elsewhere. 

Several situations fall outside the exemption: 

  • The ultimate parent jurisdiction may not have implemented Pillar Twp or may not require an information return 
  • The ultimate parent may require one but no exchange arrangement with Indonesia being in force; or 
  • A group may also have not appointed a designated filing entity other than Indonesian entity. 

In those circumstances the obligation falls on the Indonesian constituent entity, which must file the group's complete GIR locally with the DGT in OECD XML format. Where a group has more than one Indonesian constituent entity, one may be appointed to file on behalf of the others. 

The Financial Statements are Already Affected 

While the filings fall due in 2026 and 2027, the financial reporting requirements applied earlier. PSAK 212, the accounting treatment for income tax, was amended for International Tax Reform: Pillar Two Model Rules with effect from 1 December 2023, consistent with the equivalent amendment to IAS 12. The disclosure requirements apply to FY2025 financial statements. 

Two requirements operate together: 

  • A mandatory temporary exception prohibits the recognition and disclosure of deferred tax assets and liabilities arising from Pillar Two income taxes. 
  • Current tax arising under Pillar Two is recognised in the normal way and must be disclosed separately. 

Deferred tax unrelated to top-up taxes continues to be recognised and measured as before, and continues to form part of the GloBE calculation through the total deferred tax adjustment. 

Because the return will not be filed until 2027, the amount recognised in the FY2025 accounts is an estimate prepared in advance of the final computation. Auditors are requesting the supporting calculations and the evidence for any safe harbour position relied upon. Groups that have not prepared that documentation should do so now, for FY 2025 onwards. 

The OECD Side-by-Side Package and Expected Changes to PMK 136 

On 5 January 2026 the OECD Inclusive Framework agreed the Side-by-Side Package. It permits a group whose ultimate parent is located in a jurisdiction operating a qualified side-by-side regime to elect to treat top-up tax as deemed zero for IIR and UTPR purposes, for fiscal years beginning on or after 1 January 2026. Qualification requires that jurisdiction to operate both an eligible domestic and an eligible worldwide tax system, to grant foreign tax credit for qualified domestic minimum top-up taxes on equivalent terms, and to have enacted those systems before 1 January 2026. In practice the measure applies to groups headed in the United States. 

The package does not affect qualified domestic minimum top-up taxes. Indonesia's DMTT continues to apply to low-taxed Indonesian profit irrespective of the parent jurisdiction or any election the group makes, and information return obligations are unchanged. The effect in Indonesia is confined to the scope of the UTPR as it applies to US-parented groups. 

It is expected that PMK 136 or its implementing regulations to be amended to accommodate the side-by-side system. Until an amendment is issued, the relief should not be treated as available under Indonesian law, since the DGT will apply the domestic regulation as it currently stands. We will report further when an amendment is published. 

Recommended Actions 

Groups should confirm their scope position and map all constituent entities, including Indonesian entities within foreign-parented groups. Registration should be completed before 30 September 2026. The filing position for the information return should be documented in writing, a local filing entity appointed where the obligation falls to Indonesia, and the notification prepared in either case. The FY2025 & 2026 disclosure which estimates the impact of GMT should be agreed with the group reporting team and the auditors in advance, supported by the computation file and the safe harbour evidence. 

 

Contributor: T Qivi Hady Daholi, Tax Practice