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Exa: ortax.org
Exa: ortax.org
Bali Zero handles visas, company setup, tax and property compliance in Indonesia. Ask us directly on WhatsApp.
Chat with Bali Zero on WhatsAppIndonesia's Directorate General of Taxes (DJP) has published PER-6/2026, a peraturan direktur jenderal that sets out the technical and procedural requ
Indonesia's Directorate General of Taxes (DJP) has published PER-6/2026, a peraturan direktur jenderal that sets out the technical and procedural requirements for reporting under Indonesia's Global Minimum Tax framework. The regulation operationalizes Indonesia's domestic implementation of the OECD/G20 Pillar Two rules, which establish a global floor tax rate of 15 percent on the profits of large multinational enterprise groups.
The Pillar Two framework, developed through the OECD's Inclusive Framework on Base Erosion and Profit Shifting, requires participating jurisdictions to impose top-up taxes when a multinational's effective tax rate in any given country falls below the 15 percent minimum. Indonesia formally committed to this framework as part of its G20 membership obligations and has been progressively legislating its domestic implementation over recent years.
PER-6/2026 focuses specifically on the reporting mechanics: which entities must file, what information must be disclosed, the format and channels for submission, and the applicable deadlines. The regulation is expected to align with the OECD's GloBE Information Return (GIR), a standardized global reporting template designed to give tax authorities the data they need to calculate and collect top-up taxes.
The issuance of a Director General regulation at this level signals that the DJP is moving from the legislative framework phase into active enforcement posture. Previous instruments had established the legal basis; PER-6/2026 fills in the operational detail that taxpayers and their advisors need to actually prepare and submit compliant filings.
The GMT rules in Indonesia apply to constituent entities of MNE groups whose consolidated annual revenue meets or exceeds EUR 750 million in at least two of the four fiscal years immediately preceding the reporting year. Entities below this threshold are not directly subject to the new reporting obligations, though they may be indirectly affected if they form part of a larger group. Indonesia joins a growing list of jurisdictions — including EU member states, the United Kingdom, Japan, South Korea, and Australia — that have enacted or are enacting Pillar Two legislation, creating a rapidly expanding web of interlocking reporting requirements for globally operating businesses.
PER-6/2026 is a consequential step in Indonesia's tax modernization trajectory, and it arrives sooner than many foreign investors anticipated. For years, the Global Minimum Tax was discussed as a futu
re obligation; it is now a present administrative reality with named forms, deadlines, and a regulator that is clearly building enforcement capacity.
The practical pressure falls hardest on foreign-o
wned structures that were set up under older tax planning assumptions — particularly holding arrangements, intellectual property structures, or inter-company financing vehicles that historically benefited from Indonesia's relatively favorable effective tax rates in certain sectors. If an MNE group's Indonesian entities fall below the 15 percent effective rate threshold, the group now faces either a top-up tax payment in Indonesia or equivalent exposure in its ultimate parent jurisdiction.
For our clients considering Indonesian market entry or restructuring, the compliance architecture matters as much as the tax rate itself. Getting the reporting entity designation right, understanding which entities consolidate into the GloBE computation, and building the internal data infrastructure to support GIR filings are now table-stakes requirements for any serious MNE presence in Indonesia. This is not a task to delegate to a local bookkeeper; it requires coordinated advice across the group.
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