On 5 October 2026, the Large Taxpayer Office (Kanwil DJP Wajib Pajak Besar) conducted a high-level socialization session on the Global Minimum Tax (GMT) rules, also known as Pillar Two of the OECD/G20 Inclusive Framework on BEPS. The event targeted Indonesia’s top 100 corporate taxpayers, including multinational enterprise (MNE) groups with consolidated revenues exceeding EUR 750 million. The session detailed the implementation timeline for the Qualified Domestic Minimum Top-up Tax (QDMTT), the Income Inclusion Rule (IIR), and the Undertaxed Profits Rule (UTPR) as incorporated into Indonesian law through Government Regulation in Lieu of Law (Perppu) No. 1 of 2026 and its implementing regulations. Indonesia aims to enact the GMT rules for fiscal years starting on or after 1 January 2027.
Key Takeaways
- Phased Implementation: The QDMTT will apply first, ensuring that low-taxed income of MNE groups in Indonesia is topped up to the 15% minimum rate domestically before other jurisdictions apply IIR or UTPR.
- Compliance Obligations: Affected MNE groups must file a GMT information return (GloBE Information Return) within 15 months after the end of the fiscal year, with a transitional safe harbor for the first three years.
- Strategic Implications: Taxpayers are advised to review their group structures, tax incentives, and transfer pricing policies to assess GMT exposure. The DJP emphasized that early engagement and voluntary disclosure will mitigate penalty risks.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement