This publication is authored by Rödl and reflects its views and opinions. More information about Rödl is available at www.roedl.com.
Indonesia further developed its domestic framework for implementing the Global Minimum Tax (“Pillar Two”) framework through the issuance of Minister of Finance Regulation No. 136 of 2024 (“PMK-136”) on 31 December 2024 and Director General of Taxes Regulation No. PER-6/PJ/2026 (“PER-6”) on 4 May 2026. PMK-136 establishes the substantive framework for the Global Anti-Base Erosion (“GloBE”) Rules, while PER-6 provides detailed administrative procedures for taxpayer registration, Top-up Tax payments, and compliance reporting.
Indonesia’s Pillar Two framework generally applies to Multinational Enterprise (“MNE”) Groups with consolidated annual revenue of at least EUR 750 million in at least two of the four preceding fiscal years. The framework introduces a minimum Effective Tax Rate (“ETR”) of 15% through the Income Inclusion Rule (“IIR”), Domestic Minimum Top-up Tax (“DMTT”), and Undertaxed Profits Rule (“UTPR”). The IIR and DMTT apply from fiscal year 2025, while the UTPR applies from fiscal year 2026.
PER-6 provides further clarity on the administrative obligations of in-scope taxpayers, particularly the registration process, reporting requirements, and applicable compliance deadlines.
The key implementation requirements are summarized below.
GloBE Taxpayer Registration
In-scope Indonesian Constituent Entities are required to register as GloBE Taxpayers through the Taxpayer Portal (Coretax) no later than nine months after the end of their first GloBE fiscal year. For taxpayers whose first GloBE fiscal year ended on 31 December 2025, the registration deadline was 30 September 2026.
Top-up Tax Payment
Any applicable Top-up Tax under the IIR, DMTT, or UTPR must be paid within 12 months after the end of the relevant GloBE fiscal year. Accordingly, for a fiscal year ending on 31 December 2025, the payment deadline is 31 December 2026.
Annual GloBE-related Corporate Income Tax Returns
PER-6 establishes reporting procedures covering the Annual GloBE Tax Return, DMTT Annual Corporate Income Tax Return, and UTPR Annual Corporate Income Tax Return, depending on the taxpayer’s position and applicable obligations. The UTPR reporting requirements apply from fiscal year 2026 onwards.
These returns are generally due within 16 months after the end of the relevant GloBE fiscal year, reflecting the filing deadline of four months after the subsequent GloBE Tax Year (i.e., the tax year following the year to which the GloBE rules apply). For the first GloBE fiscal year, a filing extension of up to two months may be available subject to the applicable procedures.
GloBE Information Return (“GIR”) and GIR Notification
PER-6 also regulates the submission of the GIR and related Notification. The GIR contains information concerning the MNE Group’s Constituent Entities, jurisdictional ETR calculations, and Top-up Tax allocation. Where the GIR is submitted by a designated entity, other Indonesian Constituent Entities may instead be required to submit a Notification identifying the relevant filing entity.
The GIR and Notification are generally due within 15 months after the end of the GloBE fiscal year, extended to 18 months for the first GloBE fiscal year.
The issuance of PMK-136 and PER-6 marks an important development in Indonesia’s implementation of Pillar Two framework, providing greater clarity regarding the applicable tax mechanisms and corresponding administrative compliance obligations. In-scope MNE Groups should assess the impact of these regulations on their Indonesian Constituent Entities, evaluate potential Top-up Tax exposure, and ensure readiness for the upcoming compliance procedures to meet the relevant deadlines.
For inquiries, please contact:
- Reinaldo Samuel AP Sitorus
Senior Manager
Transfer Pricing & International Tax
Roedl Tax Consulting
T +62 21 5056 0405 reinaldo.samuel@roedl-indonesia.com
- Vita Surya Nirmala
Senior Associate
Legal Practice
Andi Gunawan & Associates
in association with RÖDL
T +62 21 5056 0405 vita.surya@roedl-indonesia.com
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