Why You Need Qualified Tax Support to Address Your SP2DK Response Letter

Receiving an SP2DK doesn’t automatically mean your company is under a tax audit. However, how you prepare your SP2DK response letter can determine whether the issue is clarified efficiently or requires further attention from the Directorate General of Taxes (DJP). 

Since January 1, 2026, PMK 111/2025 generally gives taxpayers 14 days to respond, with a possible extension of up to 7 additional days if the required written notification is submitted on time. 

For businesses, the priority should therefore not be simply responding before the deadline. The explanation, tax position, supporting documents, and underlying accounting records should work together to address the issue raised by DJP. 

Key Takeaways

• An SP2DK response letter should address the specific discrepancy identified by DJP, not simply acknowledge receipt of the SP2DK. 
• Under PMK 111/2025, taxpayers generally have 14 days to respond, with a possible extension of up to 7 additional days when the required notification is submitted on time. 
• Businesses should first determine whether the discrepancy reflects an actual tax exposure, a timing issue, a reporting difference, third-party data, or another explainable cause. 
• If the SP2DK issue remains unresolved, DJP may request further clarification, conduct a visit, take additional compliance action, or propose a tax audit. 
• InCorp Indonesia (an Ascentium Company) can support businesses with SP2DK assessment, reconciliation, response preparation, supporting documents, and follow-up discussions with DJP. 

Overview of the SP2DK Response Letter 

Area	Position	What Businesses Should Do
Purpose	Respond to data or information identified by DJP and, where applicable, fulfil the related tax obligation	Address the specific discrepancy rather than submit a general explanation
Response deadline	Generally, 14 days under PMK 111/2025	Start reviewing the issue and supporting records as soon as the SP2DK is received
Extension	Up to 7 additional days may be available when the required written notification is submitted on time	Notify the issuing KPP before the original response period expires
Response content	May include an explanation of the identified data, fulfilment of tax obligations, or both	Match the response to the issue raised by DJP
Supporting evidence	Relevant evidence should support the taxpayer’s explanation and position	Reconcile tax filings with accounting records, contracts, invoices, and transaction documents
Tax position	The taxpayer may agree with, clarify, or support a different position from the data identified by DJP	Assess the tax treatment before making any correction or payment
After submission	DJP may accept the clarification, request further information, conduct further discussion or a visit, or take other follow-up action	Keep the full response file and supporting documents ready for further clarification
If unresolved	The matter may progress to additional compliance action or a proposed tax audit	Address inconsistencies early and maintain a well-supported, consistent tax position

An SP2DK response letter is the formal response a taxpayer submits after receiving a Surat Permintaan Penjelasan atas Data dan/atau Keterangan from DJP. 

DJP generally issues an SP2DK when its compliance review identifies data or information indicating a possible unfulfilled tax obligation. Under PMK 111/2025, the response can consist of an explanation of the identified data, fulfilment of the relevant tax obligation, or both. 

PMK 111/2025 also provides a standard response format as part of Indonesia’s updated tax compliance supervision framework. 

Why the SP2DK Response Letter Matters 

The main risk is not simply receiving an SP2DK. Problems often arise when a company responds before understanding why its reported information differs from the data available to DJP. 

A poorly prepared response to an SP2DK can leave important questions unresolved, such as discrepancies in financial records or tax filings, which may lead to additional audits or penalties. Concrete examples help illustrate the importance of a thorough and accurate response. 

The response should therefore do more than meet the deadline. It should clearly address the discrepancy, establish the company’s tax position, and support that position with relevant evidence. 

If the issue remains unresolved, DJP may continue the compliance process and take further action depending on its findings. 

READ MORE:

• What Happens After SP2DK? Tax Issues, Outcomes, and Audit Risks 
• Strengthen Tax Representation in Indonesia under PMK 44/2026 
• Tax Supervision in Indonesia: From SP2DK to Audit and Assessment 

What Should Be Included in an SP2DK Response Letter? 

Under PMK 111/2025, an SP2DK response letter may contain an explanation of the data or information identified by DJP, fulfilment of the relevant tax obligations, or both. 

Explanation of Data or Information 

Where the taxpayer provides clarification, the response should include: 

• An explanation addressing the data or information requested by DJP. 
• Attachment I, containing the main explanation of the DJP findings. 
• Attachment II, containing additional data or information, where applicable. 
• Relevant evidence supporting the explanation provided. 

The explanation should be objective and consistent with the taxpayer’s accounting records, tax filings, and supporting documents. 

Fulfilment of Tax Obligations 

If the taxpayer chooses to fulfil the relevant tax obligation, the response may include, depending on the circumstances: 

• Registration for an NPWP or activation of NIK as an NPWP. 
• Tax withholding and/or collection. 
• Tax payment or deposit. 
• Submission of the relevant tax return (SPT). 
• Registration as a Taxable Entrepreneur (PKP). 
• Registration of a Land and Building Tax (PBB) object. 

The response should address the specific issues raised in the SP2DK and be supported by appropriate documentation. 

How to Prepare a Strong SP2DK Response Letter 

A strong SP2DK response starts before you draft the letter. Problems can arise when businesses respond without first identifying the source of the discrepancy, reconciling the relevant records, or establishing a supportable tax position. 

Identify the Exact Discrepancy 

Review each issue raised in the SP2DK and determine which transaction, tax period, tax type, or reporting position is involved. 

Reconcile DJP Data with Company Records 

Compare the information in the SP2DK against the company’s: 

• Tax returns 
• General ledger 
• Financial statements 
• Invoices and tax invoices 
• Withholding documents 
• Contracts and agreements 
• Bank or transaction records 

This helps determine whether the difference comes from actual tax exposure, a timing difference, reporting classification, third-party data, or another explainable cause. 

Determine the Company’s Tax Position 

Do not automatically correct a tax return simply because an SP2DK has been received. 

First determine whether the company’s original treatment remains supportable under the applicable tax regulations or whether additional tax fulfilment is required. 

Build the Response Around Evidence 

Each material explanation should be connected to supporting documents. When the taxpayer disagrees with DJP’s data or interpretation, supporting evidence becomes particularly important. 

Keep the Explanation Consistent 

The response letter, financial records, tax filings, attachments, and verbal explanations during any subsequent discussion should tell the same story. Inconsistencies can create additional questions instead of resolving the original issue. 

Manage the Deadline Carefully 

Under PMK 111/2025, the standard response period is 14 days, calculated using the method used to deliver the SP2DK. A taxpayer may request an extension of up to 7 days, provided the issuing KPP receives the written extension notification before the initial response period expires. 

What Happens If the SP2DK Response Doesn’t Resolve the Issue? 

Submitting an SP2DK response letter doesn’t automatically close the case. 

DJP will first assess the explanation, supporting evidence, and any tax obligations the taxpayer has fulfilled. Depending on the findings, several outcomes are possible: 

• The clarification is sufficient, and the issue is closed. 
• The company fulfils or corrects the relevant tax obligation. 
• DJP requests further clarification or supporting information. 
• A further discussion or visit takes place. 
• Another compliance action is required based on the information identified. 
• The matter is proposed for a tax audit when formal examination is considered necessary. 

PMK 111/2025 also allows DJP to continue the compliance discussion and calculate the indicated tax obligation when a taxpayer fails to respond or participate as required. 

Companies should therefore retain the full response file and monitor the formal outcome, rather than assuming submission itself ends with the SP2DK process. 

How InCorp Can Support Your SP2DK Response Letter 

SP2DK cases may require identifying the source of a discrepancy, quantifying potential exposure, assessing applicable tax rules, preparing evidence, and determining how the response may affect subsequent tax periods. 

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

• Reviewing the SP2DK and identifying tax issues that require clarification. 
• Reconciling DJP findings against tax returns, accounting records, and supporting documentation. 
• Assessing the company’s tax position and potential exposure. 
• Preparing the SP2DK response letter and supporting document package. 
• Supporting discussions and follow-up clarification with the tax authority. 
• Preparing the company for further tax review or audit if the issue progresses. 

Our tax team includes experienced professionals with USKP certification, Brevet tax qualifications, and hands-on experience handling SP2DK cases and Indonesian tax matters. 

READ MORE:

• SP2DK Case Study: How InCorp Reduced a Tax Correction by 92%

If your company has received an SP2DK, an early assessment can help identify the underlying issue, organise the supporting evidence, and prepare a well-supported response before the deadline. 

Talk to our tax experts to assess your SP2DK and prepare the appropriate response. Fill out the form below for a free initial consultation. 

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