Indonesia's Tax Incentive Review: What Global Minimum Tax Changes

TL;DR

Indonesia's global minimum tax framework changes the questions large multinational groups need to ask when evaluating an investment incentive.

---

The Facts

Indonesia's global minimum tax framework changes the questions large multinational groups need to ask when evaluating an investment incentive.

The Ministry of Finance announced in January 2025 that PMK 136/2024 introduces a 15% minimum tax framework for multinational groups meeting the EUR 750 million consolidated revenue threshold, beginning with the 2025 tax year. The regulation contains the detailed scope and calculation rules. Foreign ownership alone does not establish that a business falls within that framework. Ministry of Finance announcement · PMK 136/2024.

Why incentive design matters

An investment model cannot safely equate a local tax reduction with the same reduction in the group's final tax burden. For an in-scope group, potential top-up tax and the treatment of an incentive must be assessed together.

An official Ministry of Finance report on its April 2026 forum discusses how evolving OECD rules affect Indonesian incentive design. It describes consideration of substance-based incentives and the need to adjust domestic provisions. This records a policy discussion, not an incentive award available to every company. Ministry of Finance, April 2026.

Start with the group's actual position

Our recommendation is to organise the review around three documents: the group structure, the relevant consolidated revenue history, and the written terms of the Indonesian incentive.

Ask the group tax team to confirm scope before modelling a benefit. Then compare the existing position with a scenario that includes applicable top-up tax. Treat any proposed replacement incentive as a separate scenario until its governing provisions and availability are established.

For a smaller standalone Bali business, this news is not evidence that its ordinary corporate tax rate has suddenly become 15%. For a Bali subsidiary belonging to a large international group, local turnover alone may be an inadequate starting point.

The investment decision should follow a documented group assessment and the incentive's actual terms, rather than a headline percentage.

Primary Source

Exa: taxindo.co.id

---