Indonesia has moved its global minimum tax regime from substantive rules to filing mechanics. PER-6/PJ/2026, effective 4 May 2026, implements Minister of Finance Regulation No. 136 of 2024 for multinational groups whose consolidated revenue reaches EUR750 million in at least two of the four preceding fiscal years. The regime applies a 15% minimum effective tax rate through the Income Inclusion Rule and Domestic Minimum Top-up Tax from 2025, with the Undertaxed Profits Rule applying from 2026.
The implementing regulation prescribes electronic GloBE income-tax returns, an XML GloBE Information Return and a separate notification route. The ordinary GIR and notification deadline is 15 months after the end of the GloBE year, extended to 18 months for a group's first year in scope. Indonesian constituent entities should also determine which GloBE, domestic top-up tax and UTPR return components apply and coordinate any foreign-parent filing or exchange arrangement.
Groups should now move beyond high-level scoping. A practical readiness exercise should map constituent entities and ownership, reconcile local and group data, test the treatment of incentives and deferred tax, allocate responsibility for elections and filings, and confirm that evidence can be produced through the tax authority's electronic process. Transaction models involving Indonesian tax incentives should also be revisited because a nominal incentive may not produce the same benefit after a jurisdictional top-up-tax calculation.
This publication does not constitute legal advice and should not be relied on as a substitute for advice on specific circumstances.