On 11 August 2026, the Kanwil DJP West Java I announced that tax enforcement proceedings against corporate taxpayer SBAT culminated in a court conviction for tax evasion (kecurangan pajak). The case, adjudicated under Article 39 of Law No. 28 of 2007 on General Provisions and Tax Procedures (KUP Law) as amended by Law No. 7 of 2021 (UU HPP), represents a significant victory for the DJP’s criminal enforcement division. The prosecution demonstrated that SBAT deliberately falsified financial records and underreported taxable income across multiple fiscal years, resulting in substantial state revenue losses. The court’s decision imposes both criminal penalties (imprisonment for responsible executives) and administrative sanctions (recovery of tax underpayments plus 200% penalty surcharge under Article 17 KUP Law). This case follows DJP’s intensified focus on corporate criminal liability under the UU HPP framework, which expanded the scope of punishable tax crimes and increased maximum penalties.
Key Takeaways
- Corporate Criminal Liability Confirmed: The verdict reinforces that corporations and their management face criminal exposure for systematic tax fraud, not merely administrative fines.
- Enhanced Deterrence: The 200% penalty surcharge plus asset recovery creates a powerful financial deterrent, aligning Indonesia’s enforcement with international standards (OECD Model Tax Convention Article 26).
- Evidence Standards: The conviction relied on forensic accounting and digital evidence from DJP’s upgraded audit systems, signaling heightened investigative capacity.
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
