Tax Audit in Indonesia: Key Updates Under the Latest Regulation

Tax audits are a crucial mechanism for ensuring fiscal compliance and accountability. In Indonesia, the government recently enacted Minister of Finance Regulation No. 15 of 2025 (PMK No. 15 of 2025), introducing meaningful reforms to the tax audit framework. These updates aim to modernize procedures, strengthen transparency, and support businesses in understanding evolving compliance obligations. 

What’s New in Indonesia’s Tax Audit Process 

Indonesia has updated its tax audit rules through PMK No. 15 of 2025. The new system clarifies audits by grouping them into three types: comprehensive, focused, and specific. Each type now has a fixed time limit, helping businesses understand what to expect. The process is faster, with shorter deadlines and limited extensions allowed. 

Another key change is a required meeting between the tax office and the taxpayer before the audit is finalized. This provides businesses with an opportunity to respond to any findings early. Many parts of the audit are now handled online through the Coretax system, making everything more efficient, but also requiring digital readiness from businesses. 

READ MORE:

• Tax Compliance in Indonesia: A Comprehensive Guide for Businesses and Individuals
• Pre-Tax Litigation Explained: Processes, Benefits, and Insights
• What to Expect in 2025 for the Core Tax Administration System

New Audit Types and Timelines You Need to Know 

The latest PMK No. 15 of 2025 introduces a simplified structure for tax compliance audits in Indonesia, replacing the older field and office audit system. The audit process is now categorized into three clear types, each with defined scopes and timelines: 

Audit Type	Scope	Timeline
Comprehensive	Covers the full Tax Return or Tax Object Notification (SPOP)	5 months testing + 30 working days reporting
Focused	Examines selected items in depth, initiated with official notification	3 months testing + 30 working days reporting
Specific	Targets selected items in a simpler manner	1 month + 30 working days  10 + 10 working days (for concrete data)*

*Concrete data audits apply to issues like unreported invoices or tax slips, based on verified transactional data. 

Regulatory Changes 

• Transfer pricing or group company audits may receive up to a 4-month extension, down from the previous 6-month maximum. 
• Audits for non-compliance purposes now follow a total duration of 4 months, including both testing and reporting. 
• Audits related to the oil and gas industry remain governed by specific regulations (MoF Reg. No. 34/2018 and 94/2023). 
• The older classification into field, office, and concrete audits is no longer used under PMK 15. 

This updated structure offers more predictability and transparency for businesses undergoing a tax audit, helping them better manage compliance obligations. 

Document Submission Requirements 

Here are the updated document submission rules under PMK No. 15 of 2025 to support your tax audit procedures: 

One-Month Primary Deadline 

Taxpayers must provide all requested documents within 1 month of notification. After this, items are considered “not provided” unless exceptions apply. 

Exceptions for Special Documents 

• Documents not yet available from third parties? Submit before the PAHP closing conference. 
• Additional or supporting documents (not initially requested) may also be provided before PAHP minutes are signed. 

Consequences of Missing Documents 

If key documents are not submitted on time, auditors may: 

• Conduct a limited audit based on available data, or 
• Issue an ex-officio assessment of taxable income; and, if tax evasion is suspected, 
• Initiate a preliminary evidence audit (Bukper)  

Electronic and Physical Document Submission 

Documents can be submitted via: 

• Coretax electronic system, 
• Direct delivery to the tax office, or 
• Mail with proof of delivery. 
• However, SPHP (preliminary findings) and responses must be submitted electronically or in person or by fax—postal delivery is no longer permitted. 

Maintaining organized records and meeting all deadlines is crucial to ensuring full compliance and avoiding costly penalties during your business tax audit. For expert assistance in navigating these requirements, consider leveraging InCorp’s services, which offer professional guidance tailored to your tax needs in Indonesia. 

Implications for Businesses and Compliance Strategy 

The latest updates to Indonesia’s tax audit rules demand a more agile and prepared response from businesses of all sizes. With tighter deadlines, structured audit types, and digital integration, the approach to managing tax compliance must evolve. 

• Strengthen Internal Controls: Ensure accurate and timely reporting across all tax obligations. Regular internal reviews and reconciliations are more critical than ever. 
• Digital Readiness: Embrace systems compatible with Coretax to manage audits electronically. Maintain digital backups of tax documents for quick access. 
• Audit-Ready Documentation: Organize and index all supporting documents—even those not initially requested—to prepare last-minute or surprise requests during the audit period. 
• Proactive Risk Assessment: Conduct early mock audits or gap analyses to detect potential compliance issues. This reduces the chance of negative findings during an official audit. 
• Timely Engagement with Tax Experts: With compressed timelines and more complex regulations, seeking guidance from qualified professionals can prevent errors and penalties. 

Expert support is essential and non-negotiable for success. InCorp Indonesia (an Ascentium Company) delivers tax consulting services that ensure you gain insights, compliance support, and strategic planning for your upcoming business tax audit.

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