On 12 October 2026, the DJP conducted a specialized tax education session for the Marubeni Group, a major Japanese multinational conglomerate operating across energy, infrastructure, and consumer sectors in Indonesia. The session covered two critical regulatory domains: the implementation of the Global Minimum Tax (GMT) under PMK-136/PMK.03/2024, aligning with OECD Pillar Two GloBE Rules, and the procedural updates for Annual Corporate Income Tax Return (SPT Tahunan PPh Badan) filing for fiscal year 2025. Marubeni’s Indonesian entities, with consolidated group revenue exceeding the EUR 750 million threshold, are subject to the Qualified Domestic Minimum Top-up Tax (QDMTT) mechanism effective 1 January 2025. The training detailed the computation of GloBE Income, Adjusted Covered Taxes, and the Top-up Tax liability, alongside the new e-SPT Badan 2025 form structure incorporating GMT schedules. Additionally, DJP clarified the interaction between GMT obligations and existing tax treaty benefits under the Indonesia-Japan Double Tax Agreement (DTA).
Key Takeaways
- GloBE Compliance Calendar: Marubeni must submit GloBE Information Return within 15 months after fiscal year-end, with Top-up Tax payment due concurrently with annual CIT settlement.
- Transitional Safe Harbor Relief: The session explained the Transitional CbCR Safe Harbor, Transitional UTPR Safe Harbor, and Transitional QDMTT Safe Harbor tests for FY 2025–2027, potentially eliminating Top-up Tax for qualifying jurisdictions.
- Transfer Pricing Alignment: DJP emphasized consistency between Local File, Master File, and CbCR data with GloBE financial accounting standards (IFRS/GAAP) to avoid transfer pricing adjustments triggering additional Top-up Tax exposure.
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