At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-26. Tax authority: Direktorat Jenderal Pajak (DJP, Directorate General of Taxes), Ministry of Finance. Summaries are simplified; check the linked official source before relying on them.
The law
#The arm's length rule is in Income Tax Law art. 18(3), as amended by Law 7/2021. It lets the Director General of Taxes redetermine income and deductions, and treat debt as capital, for taxpayers with a special relationship, using what independent parties would do. A special relationship exists at 25% direct or indirect ownership, by control, or through close family ties (art. 18(4); PMK 172/2023 art. 2). PMK 172/2023 (in force since 29 December 2023) is the main regulation. It sets six steps for applying the principle (art. 4(4)), a preliminary test for services, intangibles, loans and similar deals (arts. 13 and 14), the documentation rules, audit powers, and the APA and MAP procedures. Each type of transaction is tested separately, using the facts at the time the price is set (art. 4).
Documentation
#There are three documents: the master file, the local file and the country-by-country report (PMK 172/2023 art. 16(2)). A taxpayer with affiliate transactions must keep a master file and local file if, in the prior year, it had turnover above IDR 50bn, tangible goods deals with affiliates above IDR 20bn, services, interest, intangibles or other deals above IDR 5bn each, or an affiliate in a lower tax country (art. 16(3)). The files must be available within 4 months after the year end, with a signed availability statement, and a summary (ikhtisar) goes with the corporate income tax return (arts. 18 and 19). The DJP can ask for them, and the taxpayer has 1 month to hand them over in a compliance check or audit (art. 34). They must be in Indonesian, unless the taxpayer has Ministry of Finance approval to keep books in a foreign language, and then a translation is added (art. 32). Below the thresholds there is no file duty, but the arm's length principle still applies (art. 16(7)).
Methods
#The methods are CUP, resale price and cost plus, plus other methods such as profit split, TNMM, comparable uncontrolled transaction, asset valuation and business valuation (art. 9(1)). The most reliable method is used, and if two are equally reliable, CUP or CUT comes first, then resale price or cost plus, then profit split or TNMM (art. 9(12) and (13)). TNMM is allowed when reliable comparables at price or gross profit level are not available (art. 9(7)), and internal comparables are preferred (art. 8(8)). The range is the full range for two comparables and the interquartile range for three or more (art. 12(6)). If the price is outside the range, it is moved to the arm's length point, the most appropriate point in the range, or the median if no most appropriate point can be found (art. 12(7)). A service, intangible or loan that fails the preliminary test is treated as not arm's length (art. 14).
Penalties
#PMK 172/2023 sets no fine of its own. Missing or late documents, or missing the 1 month request deadline, bring sanctions under general tax law (arts. 28 and 35). The DJP can redetermine income, testing the documents if they exist or the actual facts if they do not (art. 36). The gap between the non arm's length value and the arm's length value is treated as an indirect profit distribution taxed as a dividend (art. 37), unless cash is returned before the assessment letter. Underpaid tax can be assessed within 5 years, with monthly interest at the reference rate plus 15%, divided by 12, for up to 24 months (KUP art. 13(1), (2) and (2b)). A late corporate annual return costs IDR 1,000,000 (KUP art. 7(1)).
Pillar Two
#PMK 136/2024 applies the IIR and the domestic minimum top-up tax (DMTT) from 1 January 2025 and the UTPR from 1 January 2026 (arts. 73 and 74), to groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 prior years. A group entity applies for GloBE taxpayer status within 9 months after the end of the first GloBE year (PER-6/PJ/2026 art. 4). Each year the Indonesian entities file a GloBE annual income tax return (GloBE part for the parent, DMTT part for every entity, UTPR part if tax is allocated), plus a GIR, or a notification if someone else files the GIR. The return is due 4 months after the end of the year following the GloBE year, and the top-up tax is paid in rupiah by the end of that same year (PER-6 arts. 11 and 20). The GIR and notification are due 15 months after the GloBE year end, or 18 months for the first GloBE year, which for groups already in scope is the first fiscal year starting in 2025 (PMK 136 art. 69; PER-6 arts. 13 and 15). For that first year the return can also be extended by 2 months by notice. Administrative sanctions on the designated filing entity are waived for tax years starting on or before 31 December 2026 and ending by 30 June 2028 (PMK 136 art. 70).
Other rules
#The APA program allows unilateral, bilateral and multilateral agreements for up to 5 tax years plus a roll-back, filed 12 to 6 months before the period, after 3 years of filed returns and master and local files (PMK 172/2023 arts. 55 and 56). Mutual agreement requests follow the treaty time limit, or 3 years if the treaty is silent (art. 42). The same regulation covers a related-party VAT price adjustment (art. 39) and domestic permanent establishment rules (art. 15). Indonesia moves a deadline that falls on a weekend or holiday only for monthly tax payments and monthly returns (PMK 81/2024 arts. 100 and 173). That rule counts Saturday, Sunday, national holidays, election holidays and national collective leave (cuti bersama), but the annual, TP and Pillar Two filings here are not covered by it.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Master file (dokumen induk) Must be available no later than 4 months after the end of the tax year, with a signed statement of when it became available (art. 18(1) and (3)). It is built from data available when the transactions took place (art. 17(1)). It must be in Indonesian unless the taxpayer has Ministry of Finance approval for foreign language books (art. 32). Content is set by art. 29 and Lampiran D. The DJP can request it, and the taxpayer then has 1 month (art. 34). | 4 months after year end (e.g. Apr 30, 2026) | Taxpayers with affiliate transactions where, in the prior year, gross turnover was above IDR 50bn, or tangible goods transactions were above IDR 20bn, or services, interest, intangibles or other affiliate transactions were above IDR 5bn each, or an affiliate is in a country with a lower income tax rate (PMK 172/2023 art. 16(3)). The tool cannot test these alternatives, so it shows this for every company. | PMK 172/2023 arts. 16 to 18, 29 and 32 (DJP) |
| 2 | Local file (dokumen lokal) Must be available no later than 4 months after the end of the tax year, with a signed statement of when it became available (art. 18(1) and (3)). It must show how the arm's length principle was applied (art. 30(1)(c)), split by business line if the characterisation differs (art. 30(3)). It is in Indonesian (art. 32). Below the thresholds there is no file duty, but the arm's length principle still applies (art. 16(7)). | 4 months after year end (e.g. Apr 30, 2026) | Same test as the master file (PMK 172/2023 art. 16(3)): turnover above IDR 50bn, or affiliate transactions above IDR 20bn for tangible goods or IDR 5bn for each other type, or an affiliate in a lower tax country. The tool shows this for every company. | PMK 172/2023 arts. 16 to 18, 30 and 32 (DJP) |
| 3 | Corporate income tax annual return (SPT Tahunan PPh Badan) Due 4 months after the end of the tax year, so 30 April for a calendar year (PMK 81/2024 art. 169(2)). A notice of extension, filed before that date, adds up to 2 months (arts. 174 and 175). Tax due must be paid in full before the return is filed, and no later than the filing deadline (art. 95(1)). The master and local file summary and the CbC receipt go with this return. The weekend and holiday rule in arts. 100 and 173 covers only monthly payments and returns, so an annual deadline on a weekend or holiday does not move. A late return costs IDR 1,000,000 (KUP art. 7(1)). | Extended: notice of extension filed before the 4 month deadline, with a provisional tax calculation, provisional accounts and proof of payment of any tax due (PMK 81/2024 arts. 174 and 175) (e.g. Jun 30, 2026); original due date Apr 30, 2026 | All corporate taxpayers in Indonesia (wajib pajak badan), including permanent establishments. | PMK 81/2024 arts. 169, 174 and 175 (DJP) |
| 4 | Summary of the master and local file (ikhtisar) and availability statement A summary of the master and local file must be made and filed as an attachment to the corporate income tax return for the same year (art. 19(1) and (2)), in the format of Lampiran B (art. 19(4)). The signed statement on when the files became available goes with the files (art. 18(3)). Because the return can be extended, the extended date applies to this summary, but the files themselves must still exist within 4 months. | With Corporate income tax annual return (SPT Tahunan PPh Badan) (extended) (e.g. Jun 30, 2026); original due date Apr 30, 2026 | Taxpayers that must keep a master file and local file (PMK 172/2023 art. 16(3)). | PMK 172/2023 arts. 18 and 19 (DJP) |
| 5 | Application to add GloBE taxpayer status (penambahan status Wajib Pajak GloBE) A one-time application through the Taxpayer Portal, filed no later than 9 months after the end of the first GloBE year in which the group meets the scope test (PER-6/PJ/2026 arts. 3 and 4). A GloBE year (Tahun Pengenaan GloBE) is a year in which GloBE is imposed in Indonesia, so for a group already in scope the first one is its first fiscal year starting on or after 1 January 2025. For a calendar group the date was 30 September 2026. If the entity does not apply, the tax office can add the status itself (art. 4(7)). A group that first comes into scope later has its own first year, which the tool does not show. | 9 months after year end (first year) (e.g. Sep 30, 2026) | Constituent entities in Indonesia of multinational groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 prior tax years (PMK 136/2024 art. 2(1)). Applies from tax years 2025 (IIR and DMTT) and 2026 (UTPR). | PER-6/PJ/2026 art. 4 (DJP) |
| 6 | CbC notification (notifikasi laporan per negara) Filed through the Taxpayer Portal no later than 12 months after the end of the tax year (art. 23(4)). It says whether the entity is the parent or a constituent entity and who files the report, in the format of Lampiran C (art. 24). A foreign parent's Indonesian entity also uses it to name a surrogate parent abroad (art. 21(2)(a)). PMK 172/2023 has no weekend rule for this date. | 12 months after year end (e.g. Dec 31, 2026) | Every Indonesian taxpayer that is a member of a group or has affiliate transactions covered by a CbC report (art. 23(1)). A CbC report is required for groups with consolidated revenue of at least IDR 11 trillion (Indonesian parent) or EUR 750m, or the parent country's threshold (foreign parent) in the prior year (arts. 16(4) and 22(1)(d)). The tool uses IDR 11 trillion. | PMK 172/2023 arts. 21 to 24 (DJP) |
| 7 | Country-by-country report (laporan per negara) Filed with the notification through the Taxpayer Portal no later than 12 months after the end of the tax year (arts. 18(2) and 23(2) and (4)), in XML with a working paper (art. 25). The receipt is attached to the next year's corporate income tax return (arts. 19(3) and 23(6)). If the report cannot be obtained through exchange, a foreign parent's local entity has 3 months after the DJP publishes the list of such countries (art. 22(4)). The parent cannot name another entity to file for it (art. 20(2)). | 12 months after year end (e.g. Dec 31, 2026) | Indonesian resident parent entity of a group with consolidated gross revenue of at least IDR 11 trillion in the prior year (art. 16(4)). An Indonesian entity of a foreign parent files only if the parent country has no CbC duty, no exchange agreement, or the report cannot be obtained (art. 16(5)). | PMK 172/2023 arts. 16 to 25 (DJP) |
| 8 | Payment of top-up tax (IIR, DMTT, UTPR) Top-up tax of a GloBE year is due in the following tax year and must be paid by the end of that year (PMK 136 art. 65(16) and (17); PER-6 art. 20). For a calendar group, 2025 tax is paid by 31 December 2026. Pay in rupiah with account code 411618 and deposit code 610 (IIR), 620 (UTPR) or 630 (DMTT). Tax due must also be paid before the return or an extension notice is filed. The weekend payment rule in PMK 81 art. 100 covers only the monthly payments in art. 94. | 12 months after year end (e.g. Dec 31, 2026) | Constituent entities in Indonesia of multinational groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 prior tax years (PMK 136/2024 art. 2(1)). Applies from tax years 2025 (IIR and DMTT) and 2026 (UTPR). | PER-6/PJ/2026 art. 20 and PMK 136/2024 art. 65 (DJP) |
| 9 | GloBE annual income tax return (SPT Tahunan PPh GloBE, DMTT and UTPR) The return reports the top-up tax of the GloBE year as a return of the following tax year, the GloBE tax year, and is due 4 months after the end of that year (PMK 136 art. 65(13) and (14); PER-6 art. 11(1)). For a calendar group, the 2025 GloBE year gives a return due 30 April 2027. For the first GloBE year only, a notice of extension filed before that date, with proof that any top-up tax due is paid, adds up to 2 months (PMK 136 art. 69(2); PER-6 art. 11(2) to (4)); the tool does not add this, because it is not automatic. The parent files the GloBE part, every entity files the DMTT part, and the UTPR part is filed only if UTPR tax is allocated. The date counts from the ultimate parent's year end, and no weekend rule covers annual returns. Late filing or late payment brings sanctions under general tax law (PMK 136 art. 66), but sanctions on the designated filing entity are waived for tax years starting on or before 31 December 2026 and ending by 30 June 2028 (PMK 136 art. 70). | 16 months after year end (e.g. Apr 30, 2027) | Constituent entities in Indonesia of multinational groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 prior tax years (PMK 136/2024 art. 2(1)). Applies from tax years 2025 (IIR and DMTT) and 2026 (UTPR). | PMK 136/2024 arts. 65 and 69, PER-6/PJ/2026 arts. 7 and 11 (DJP) |
| 10 | GloBE Information Return (GIR) Filed in XML through the Taxpayer Portal 15 months after the end of the GloBE year, or 18 months for the first GloBE year in which the group is in scope (PER-6 art. 13; PMK 136 art. 69(1)). GloBE years start in Indonesia with fiscal years from 2025, so the tool uses 18 months for year ends from 31 December 2025 to 30 December 2026 (30 June 2027 for a calendar 2025 year). The Indonesian ultimate parent files it. For a foreign parent, one Indonesian entity files if the group names it as the filing entity, or if the filing entity's country has no qualifying competent authority agreement with Indonesia (PMK 136 art. 65(8)). The receipt goes with the GloBE annual return. The date counts from the ultimate parent's year end (PER-6 art. 29(2)). No weekend rule covers this date. | 18 months after year end (first year) (e.g. Jun 30, 2027) | Constituent entities in Indonesia of multinational groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 prior tax years (PMK 136/2024 art. 2(1)). Applies from tax years 2025 (IIR and DMTT) and 2026 (UTPR). | PMK 136/2024 arts. 65 and 69, PER-6/PJ/2026 arts. 12 and 13 (DJP) |
| 11 | GloBE notification (Notifikasi) Every GloBE taxpayer in Indonesia that does not file the GIR itself sends an electronic notification, 15 months after the GloBE year end, or 18 months for the first GloBE year in which the group is in scope (PMK 136 art. 65(5) and (10); PER-6 arts. 14 and 15). The tool uses 18 months for year ends from 31 December 2025 to 30 December 2026. It names the ultimate parent and the entity that files the GIR. An entity in more than one group files one notification per group. The receipt goes with the GloBE annual return. | 18 months after year end (first year) (e.g. Jun 30, 2027) | Constituent entities in Indonesia of multinational groups with consolidated revenue of at least EUR 750m in at least 2 of the 4 prior tax years (PMK 136/2024 art. 2(1)). Applies from tax years 2025 (IIR and DMTT) and 2026 (UTPR). Not needed by an entity that files the GIR itself. | PMK 136/2024 art. 65, PER-6/PJ/2026 arts. 14 and 15 (DJP) |
| 12 | Hand over master and local file on DJP request For compliance supervision and audit, the taxpayer must hand over the documents no later than 1 month from the date the request is delivered (PMK 172/2023 art. 34(2)). The tool uses 30 days, so count to the same date in the next month. Late delivery brings sanctions under tax law (art. 35). For other purposes the time set by general tax law applies (art. 34(3)). | Within 30 days of a tax authority request | Any taxpayer that must keep a master file and local file. | PMK 172/2023 arts. 34 and 35 (DJP) |
| 13 | UTPR part of the GloBE annual income tax return (SPT Tahunan PPh UTPR) Filed only if UTPR tax is allocated to Indonesia (art. 65(12)). It is part of the same GloBE annual return, due 4 months after the end of the GloBE tax year, so 30 April 2028 for a calendar 2026 year. The first-year 2-month extension does not apply, because the group's first GloBE year is 2025. Groups with entities in at most 6 countries and tangible assets of at most EUR 50m outside the reference country pay no UTPR during the initial phase of international activity (art. 68). | Starts with years ending on or after 2026-12-31 | Constituent entities in Indonesia of groups in scope that have UTPR top-up tax allocated to Indonesia, for GloBE years from 2026 (PMK 136/2024 arts. 65(12) and 73). | PMK 136/2024 arts. 65, 68 and 73 (DJP) |
Official texts
#- PMK 172/2023 on the arm's length principle (Peraturan Menteri Keuangan 172 Tahun 2023), DJP copy (Free of copyright: Law 28/2014 on Copyright art. 42 says there is no copyright in laws and regulations (peraturan perundang-undangan))
- PMK 136/2024 on global minimum tax and PER-6/PJ/2026 (Direktur Jenderal Pajak procedure), DJP copies (Free of copyright: Law 28/2014 on Copyright art. 42 says there is no copyright in laws and regulations (peraturan perundang-undangan))
- PMK 81/2024 on tax provisions for the core tax system (Coretax), DJP copy (Free of copyright: Law 28/2014 on Copyright art. 42 says there is no copyright in laws and regulations (peraturan perundang-undangan))
- Law 7/2021 on Harmonisation of Tax Regulations (amends the Income Tax Law and the General Tax Provisions Law) and Law 28/2007 (KUP), DJP copies (Free of copyright: Law 28/2014 on Copyright art. 42 says there is no copyright in laws and regulations (peraturan perundang-undangan))