Find Tax Discrepancies and Resolve SP2DK Issue in Indonesia

Receiving an SP2DK in Indonesia means the Directorate General of Taxes (DJP) has identified potential differences between your tax returns, financial statements, or third-party records that require clarification. 

These differences may result from reporting errors, VAT or withholding tax issues, or legitimate timing differences. Unresolved discrepancies can lead to additional tax liabilities and potential tax audits. 

Identifying which discrepancies triggered your SP2DK and reconciling taxes early helps you prepare a defensible response and prevent escalation into tax audits. 

Key Takeaways

• Tax discrepancies can trigger an SP2DK when DJP identifies inconsistencies between tax returns, financial statements, and third-party information. 
• Common tax discrepancies involve revenue, VAT, withholding tax, business expenses, and related-party transactions. 
• Tax reconciliation helps your business determine whether a discrepancy reflects a reporting error, timing difference, or legitimate transaction. 
• Under PMK 111/2025, you have 14 days to respond, with a possible extension of up to 7 days if your written notice reaches the issuing tax office before the original deadline. 
• An incomplete SP2DK response may lead to discussions, a field visit, further compliance action, or a tax audit. 

SP2DK in Indonesia: Key Compliance Points 

Compliance Point	What It Means for Your Business
Legal Basis	PMK 111/2025, effective January 1, 2026
Issued By	DJP, through the tax office (KPP) where your company is registered, generally delivered via Coretax
Common Trigger	Data in your tax returns, financial statements, or third-party reports doesn’t match
Response Deadline	14 calendar days from the earliest of issuance (with an active Coretax account), sending, or in-person delivery
Extension	Up to 7 days; your written notice must be received by the issuing KPP before the original deadline
Response Options	Explain the data with supporting evidence, and/or fulfil the obligation (e.g., amend a return or pay a shortfall)
Closure	DJP issues a completion notice (SP3 P2DK) once the clarification is resolved
If Unresolved	Discussion, field visit, audit proposal, or other follow-up action

Why an SP2DK Usually Starts with a Data Discrepancy 

An SP2DK (Surat Permintaan Penjelasan atas Data dan/atau Keterangan) is a formal clarification request issued by the DJP when potential tax reporting inconsistencies are identified. 

Through tax data matching, DJP compares tax returns, financial records, and third-party information. For example, revenue reported in your corporate income tax return may differ from the VAT tax base in your VAT returns.  

This is called revenue equalisation (ekualisasi). The difference may trigger an SP2DK even if it arises from a legitimate reason, such as an invoice issued in December for revenue recognised in January. 

Receiving an SP2DK doesn’t automatically mean a company has underpaid taxes or violated tax regulations. However, you must be able to explain the discrepancy with relevant evidence. 

READ MORE:

• Strengthen Tax Representation in Indonesia under PMK 44/2026 
• Tax Supervision in Indonesia: From SP2DK to Audit and Assessment 
• How to Handle SP2DK and Avoid Tax Audits in Indonesia 

How DJP Identifies Tax Discrepancies 

The DJP identifies potential tax discrepancies by cross-checking information from multiple sources, including: 

• Financial Statements: Comparing reported revenue, expenses, and profits with accounting records and tax declarations. 
• Corporate Income Tax Reporting: Identifying inconsistencies between annual tax returns, taxable income calculations, and financial statements. 
• VAT Records: Matching reported sales and purchases with output VAT, input VAT, and tax invoices (e-Faktur). 
• Withholding Tax Filings: Comparing declared expenses and payments with applicable withholding tax returns and withholding slips (bukti potong). 
• Counterparty Reporting: Cross-checking transaction information reported by customers, suppliers, and other third parties. 
• Supporting Invoices or Contracts: Verifying transaction values, business purposes, and tax treatment against available supporting documentation. 

When these records do not align, DJP may issue an SP2DK requesting clarification. You can reduce potential discrepancies through periodic tax consulting and compliance reviews. 

Common Tax Discrepancies That Trigger an SP2DK 

DJP may issue an SP2DK when it finds differences in a company’s tax reporting. 

Discrepancy	What DJP Compares	Common Cause
Revenue Differences	Corporate income tax returns, VAT returns, and financial statements	Different reporting periods, non-VAT revenue, advance payments
Withholding Tax Differences	Salary, rent, and service payments against withholding tax filings	Missing withholding tax, incorrect payment classification
Unclear Business Expenses	Reported expenses against invoices, contracts, and payment records	Missing documents, non-deductible expenses
VAT Differences	Input VAT claims against suppliers’ e-Faktur records	Supplier reporting errors, incorrect tax periods
Related-Party Transactions	Intercompany payments against transfer pricing records and related-party reports	Unsupported management fees, royalties, or service charges

Identifying which category your SP2DK falls into helps you determine what evidence to gather and whether you need a correction at all. 

What Businesses Should Reconcile Before Responding to an SP2DK 

Before responding to an SP2DK, you should identify the causes of tax discrepancies and prepare supporting evidence. 

• Financial Statements and Tax Returns: Match reported revenue, expenses, and taxable income with accounting records. 
• VAT Reconciliation: Compare VAT returns with sales, purchases, and tax invoices (e-Faktur). 
• Withholding Tax Reconciliation: Verify withholding tax filings against salaries, service fees, and other payments. 
• Third-Party Data: Compare DJP findings with supplier records, customer transactions, and payment details. 
• Supporting Documents: Prepare invoices, contracts, bank statements, and explanations for identified differences. 

Businesses should confirm whether discrepancies result from reporting errors or legitimate differences before making tax corrections. Amending a return for a difference that could have been explained may result in unnecessary tax payments. 

SP2DK Response Deadlines Under PMK 111/2025 

Under PMK 111/2025, businesses must respond to an SP2DK within 14 days, with a possible 7-day extension if they submit written notification before the initial deadline. 

SP2DK responses can be submitted through Coretax or other permitted channels. Late or insufficient responses may increase the risk of further tax scrutiny. 

Received an SP2DK? Ascentium Indonesia (formerly InCorp Indonesia) can review it, reconcile the flagged data, and prepare your response before the deadline. Talk to our team → 

What Happens If Tax Discrepancies Are Not Properly Explained? 

Unresolved tax discrepancies can increase a company’s tax exposure and lead to further action by DJP, including: 

• Further Clarification Requests: DJP may request additional documents, invite you to a discussion, or conduct a field visit. 
• Additional Tax Liabilities: Confirmed underpaid taxes may result in additional payments and penalties. 
• Increased Tax Audit Risk: Unresolved discrepancies may lead to a formal tax audit. 
• Potential Tax Disputes: Tax assessments may result in objections or appeals. 
• Higher Compliance Costs: Additional reviews and documentation can increase costs and delay resolution. 

When DJP accepts your explanation, it issues an SP3 P2DK confirming the clarification is complete. Timely responses, supported by accurate tax reconciliation, are the most reliable way to achieve that outcome without an audit. 

Get Expert Support for Your SP2DK Response Before It Escalates 

Whether you are preparing for an SP2DK response or identifying potential tax reporting gaps, Ascentium Indonesia (formerly InCorp Indonesia) can help your business through: 

• Tax Discrepancy Assessment: Identify reporting gaps and potential tax liabilities. 
• Tax Reconciliation: Verify financial statements, VAT, withholding taxes, and tax returns. 
• SP2DK Response Preparation: Prepare explanations and supporting documents. 
• DJP Clarification Support: Assist with tax authority enquiries and follow-up discussions. 

Ascentium Indonesia (formerly InCorp Indonesia) has helped businesses resolve complex SP2DK cases, including an Indonesian IT services company that achieved a 92% reduction in a proposed tax correction. 

READ MORE:

• SP2DK Case Study: 92% Tax Correction Reduced Without an Audit 

Received an SP2DK? Talk to our tax experts within your response window to assess the discrepancies and prepare your response.  

Haven’t received one yet? A periodic tax reconciliation review can catch these gaps before the DJP does. 

Fill out the form below to book a free consultation. * 

*T&C apply. 

Frequently Asked Questions