Strengthen Tax Representation in Indonesia under PMK 44/2026

PMK 44/2026 changes the requirements for appointing a tax representative in Indonesia. Effective from July 7, 2026, it replaces PMK 229/2014 and introduces new rules on representative qualifications, powers of attorney, and Coretax access. 

Companies relying on internal employees or external advisers should confirm whether their representatives remain eligible, particularly as non-consultants may need a Surat Keterangan Terdaftar (SKT) after the transitional period ends on December 31, 2026.

Key Takeaways

• PMK 44/2026 has applied since July 7, 2026, and replaces PMK 229/PMK.03/2014. 
• Tax representatives are classified as licensed tax consultants, Pihak Lain (other registered parties), or qualifying family members. 
• Company employees are no longer expressly recognized as a separate representative category and may need to qualify as Pihak Lain. 
• A Surat Kuasa Khusus (special power of attorney) and Portal Wajib Pajak (DJP taxpayer portal) access serve different purposes and may both be required. 
• The temporary appointment route for certain brevet holders (tax certification holders) or tax-degree graduates ends on December 31, 2026. 

What Companies Must Address Under PMK 44/2026 

Companies should assess their current arrangements and understand the potential legal or operational risks of non-compliance with PMK 44/2026 to ensure proactive adjustments. 

Key Issue	What Companies Need to Confirm
Employee eligibility	Internal employees may need an active SKT as Pihak Lain.
December 31, 2026 deadline	Brevet or tax-degree holders must prepare a post-transition arrangement.
Power of attorney	Each Surat Kuasa Khusus must name one representative and define the tax matter.
Coretax access	System access must match the representative’s legal authority.
Delegation	The appointed representative cannot transfer to the substantive authority.
Multiple entities	Each company or tax matter may require a separate appointment.
Taxpayer liability	The taxpayer remains responsible for the obligations handled.

Companies should verify their representatives’ qualifications, appointment documents, and Coretax access before the transitional period ends on [December 31, 2026], to ensure confidence in their compliance efforts. 

What is PMK 44/2026? 

PMK 44/2026 regulates who can act as a tax representative (kuasa wajib pajak) and how they may handle specific tax matters on behalf of a taxpayer. 

A representative may assist the Directorate General of Taxes (DJP) with correspondence, tax clarification, audits, objections, document submission, and other authorized tax procedures. 

Each appointment must clearly define the tax type, period, and matter covered. However, the taxpayer remains legally responsible for all tax rights and obligations handled by the representative. 

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What Changed from PMK 229/2014? 

PMK 44/2026 shifts the focus from an individual’s relationship with the taxpayer to their qualifications, registration, and formal authority. 

Area	PMK 229/2014	PMK 44/2026
Representative categories	Tax consultants and taxpayer employees	Tax consultants, Pihak Lain, and family
Internal employees	Expressly recognized if permanent, active, and qualified	Generally, fall under Pihak Lain
Employee competency	Brevet, tax diploma, or consultant certificate	Valid SKT as Pihak Lain
Family representatives	Not expressly included	Expressly recognized
Appointment format	Primarily paper-based	Electronic or paper
Validity period	Not expressly listed as a minimum field	Must be stated
Electronic access	No comparable Portal Wajib Pajak framework	Separate access approval required
Transitional arrangement	Not applicable	Available until 31 December 2026

Under PMK 229/2014, eligible permanent employees could represent the taxpayer based on their employment status and tax qualifications. 

PMK 44/2026 removes employees as a separate category. They must generally qualify as Pihak Lain and hold an SKT to act as a formal tax representative. 

Employment status, tax experience, or Coretax access alone is no longer sufficient to represent a taxpayer before the DJP formally. 

Who Can Become a Tax Representative in Indonesia? 

PMK 44/2026 recognizes three types of tax representative: 

Licensed Tax Consultants 

A tax consultant must hold an active license, be registered with DJP, and act within the scope of that license. 

Other Registered Parties 

Pihak Lain refers to non-consultants who hold an active Surat Keterangan Terdaftar (SKT). This may include internal tax, finance, accounting, legal, or other qualified professionals. 

They must also be registered with DJP and act within the competency level stated in the SKT. 

Qualifying Family Members 

A taxpayer may appoint a spouse or a blood or marital relative up to the second degree. Family members don’t need professional tax qualifications, but a family card or taxpayer’s declaration must support the relationship. 

Can an Employee Still Represent Their Company? 

Yes, but employment status alone is no longer enough. Under PMK 44/2026, an internal tax, finance, accounting, or legal employee generally needs to qualify as Pihak Lain and hold an active Surat Keterangan Terdaftar (SKT) to represent the company before DJP formally. 

This is different from routine internal tax work. An employee may still prepare calculations, organize documents, manage deadlines, and coordinate responses. Formal representation applies when the employee acts under a Surat Kuasa Khusus for a specific tax matter. 

Companies should therefore confirm: 

• Whether the employee holds the required SKT 
• Whether the SKT covers the relevant competency level 
• Whether the appointment document is valid 
• Whether Coretax access matches the authorized scope 

Is Your In-House Tax Representative Still Qualified? 

Internal experience and Coretax access do not necessarily establish formal authority under PMK 44/2026. 

InCorp Indonesia (An Ascentium Company) can help companies assess existing representative arrangements, identify credential or documentation gaps, and prepare a compliant structure before the transitional period closes. Talk to our team -> 

PMK 44/2026 Compliance Checklist 

Before relying on a tax representative, companies should confirm: 

• The person currently representing each Indonesian entity 
• The representative’s status as a tax consultant or Pihak Lain 
• The validity of the relevant license or SKT 
• The scope and validity of the Surat Kuasa Khusus 
• Alignment between Coretax access and the authorized tax matter 
• Any employee still relying on the 2026 transitional route 
• Removal of outdated or unnecessary system access 
• The need for separate appointments across different entities or tax matters

Protect Your Tax Position with Qualified Representation 

Tax representation requires the representative’s qualifications, appointment documents, authorized scope, and Coretax access to remain aligned. 

InCorp Indonesia (an Ascentium Company) can support companies through: 

• Representation Assessment: Identify gaps in qualifications, powers of attorney, and portal access. 
• Appointment Support: Prepare the required Surat Kuasa Khusus and supporting documents. 
• Coretax Access Alignment: Match system permissions with the representative’s authorized scope. 
• DJP Correspondence Support: Assist with SP2DK, clarification requests, tax audits, and other proceedings. 
• Multi-Entity Coordination: Standardize representation arrangements across Indonesian subsidiaries. 

Talk to us to assess your tax-representation arrangement before the transitional period ends. Fill out the form below. 

Frequently Asked Questions