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Chat with Bali Zero on WhatsAppIndonesia's tax authority says automatic exchange of GloBE Information Return data is scheduled to begin in 2027. For a Bali PT PMA, the first question is whether the company belongs to a multinational group within the relevant rules—not simply whether its shareholders are foreign.
The development concerns corporate global minimum tax information. It should not be presented as a new tax imposed on every expat living in Bali.
What Indonesia has signed
The Directorate General of Taxes (DJP) announced the signing of the declaration for the GIR Multilateral Competent Authority Agreement at a conference held in Kotor, Montenegro, on 27–29 October 2026. GIR stands for GloBE Information Return. It provides a standard framework for reporting information relevant to the global minimum tax system. DJP identifies 2027 as the scheduled start of Indonesia's automatic GIR exchange. [1]
An exchange timetable is not, by itself, an individual company's filing deadline. A business still needs to establish its reporting responsibilities and the applicable filing arrangements.
Which PT PMAs should check their position?
Article 2 of PMK 136/2024 sets the general scope around constituent entities of multinational groups with consolidated annual revenue of at least EUR750 million in at least two of the four preceding tax years. The test uses the ultimate parent's consolidated financial statements. Entity exclusions and specific circumstances also require review. [2]
That is a group-level test. A relatively small Bali subsidiary may need attention if it belongs to a much larger multinational group. Conversely, foreign ownership alone does not establish that an independent Bali business meets the threshold.
For example, a Bali company within an international hospitality group should ask its group tax team to confirm the scope assessment. A standalone foreign-owned restaurant should first establish its actual group structure instead of assuming that the announcement automatically creates a GIR filing obligation. These are illustrative examples, not determinations for particular companies.
What to prepare now
The following are practical preparation suggestions:
What the announcement does not establish
It does not establish that all Bali PT PMAs must submit the same return, that every expat has a new personal tax liability, or that a tax inspection or penalty will follow automatically. The practical starting point is an accurate scope assessment, followed by a documented reporting plan for businesses that are affected.
Sources
[1] Directorate General of Taxes, announcement concerning the GIR MCAA declaration at the 27–29 October 2026 conference: https://stats.pajak.go.id/id/berita/perkuat-kerja-sama-pertukaran-informasi-perpajakan-dirjen-pajak-teken-gir-mcaa
[2] Ministry of Finance, PMK 136/2024, particularly Article 2 (scope): https://jdih.kemenkeu.go.id/dok/pmk-136-tahun-2024/view