Global Minimum Tax in Indonesia

While the Global Anti-Base Erosion (GloBE) Rules was initially introduced under PMK-136/2024, the practical administrative guidance for its implementation have only recently been issued through PER-6/PJ/2026.

A. Who is the GloBE Taxpayer?

The GloBE Taxpayer is a Constituent Entity (CE) or an entity forming part of a Joint Venture (JV) Group that is established or resident in Indonesia and is a member or part of a Multinational Enterprise (MNE) Group subject to GloBE.

B. What is the Criteria?

• Group has consolidated annual revenue of at least EUR 750 million based on the Ultimate Parent Entity’s (UPE) consolidated financial statements; and
• The threshold is met in at least two of the four fiscal years preceding the GloBE Imposition Year (the relevant fiscal year being assessed).

C. GloBE Taxpayer Status

• Required to apply for GloBE Taxpayer status no later than 9 months after the end of the first GloBE Imposition Year.
• If no application is submitted, the Indonesian Tax Authority (ITA) may assign the status based on its administrative review (ex officio).
• The status may be subject to revocation upon the taxpayer’s application or where the MNE Group no longer meets the applicable threshold requirements.
• All applications and status administration can be submitted electronically through the Taxpayer Portal (Core Tax).

D. GloBE Annual Income Tax Return

• GloBE Taxpayers are required to submit an Annual Income Tax Return (AITR) for GloBE purposes, consisting of a Main Form and supporting Attachments Forms.
• The Main Form consists of the following:

Type	Filed By	Description
GloBE Tax Return	Indonesian UPE	Includes the calculation of top-up tax under the Income Inclusion Rule (IIR) and Undertaxed Payment Rule (UTPR) on a jurisdictional basis, as well as Indonesia Domestic Minimum Top-up Tax (DMTT).
UTPR Tax Return	Indonesian Non-UPE allocated with UTPR	Includes the amount of UTPR top-up tax allocated to the relevant Indonesian GloBE Taxpayer.
DMTT Tax Return	Each Indonesian CE (including the UPE, if applicable)	Includes the de minimis exclusion, Indonesia Effective Tax Rate (ETR), taxpayer-level ETR, Indonesia DMTT top-up tax, and DMTT top-up tax allocated to the relevant GloBE Taxpayer.

• The Attachments Form consists of the following:

Attachment	Component
I	IIR Top-Up Tax Indonesian DMTT
II	UTPR Top-Up Tax allocated to the GloBE Taxpayer
III	GloBE Income/LossAdjusted Covered TaxInternational Shipping Income ExclusionSubstance-based Income Exclusion (SBIE) Additional Current Top-Up TaxDMTT Top-Up Tax for the GloBE Taxpayer

• GloBE Taxpayers must report the GloBE Imposition Year in the AITR based on the accounting period used. However, where the accounting period differs from that of the non-resident UPE, the UPE’s accounting period must be applied.
• The AITR for GloBE purposes must be submitted through Core Tax within 4 months after the end of the GloBE Fiscal Year (the year following the GloBE Imposition Year).
• For the first GloBE Imposition Year in which the MNE Group becomes subject to the GloBE Rules, taxpayers may apply for an extension of up to 2 additional months by submitting a notification before the original filing deadline.
• The AITR for GloBE purposes must be prepared in either Indonesian Rupiah or the currency used in the consolidated financial statements.
• The AITR may be amended by the GloBE Taxpayer on self-assessment basis.

E. GloBE Information Return

• In addition to the submission of the AITR, a GloBE Taxpayer acting as the UPE of an MNE Group is also required to submit a GloBE Information Return (GIR) to the ITA in soft copy Extensible Markup Language (XML) format.
• The GIR is expected to contain at least the following core information:

Component	Detail
CE Identity	Taxpayer identification number Jurisdiction of residence GloBE status
MNE Group Structure	Ownership interests among the CEs
Calculations	ETR and top-up tax for each jurisdiction and CE Top-up tax relating to JV groups The allocation of top-up tax under the IIR and the amount of top-up tax under the UTPR for each jurisdiction
GloBE Elections	Disclosures on elections made under the relevant GloBE provisions.

• If the UPE is not an Indonesian tax resident, the GIR must be submitted by an Indonesian GloBE Taxpayer where:
  • it is appointed as the Filing Constituent Entity (FCE); or
  • the FCE is located in a jurisdiction that does not have a qualifying competent authority agreement (QCAA) with Indonesia.

F. Notification

• GloBE Taxpayers are also required to submit a Notification to the ITA.
• Where a GloBE Taxpayer is a member of more than one MNE Group in a GloBE Imposition Year, a separate Notification must be submitted for each group.
• Taxpayer that have submitted a GIR is no longer subject to the Notification requirement.
• The Notification must be submitted electronically through Core Tax within 15 months after the end of the GloBE Imposition Year. For the first GloBE Imposition Year in which the MNE Group becomes subject to the GloBE Rules, the deadline is extended to 18 months after the end of the GloBE Imposition Year.

G. Top-Up Tax Payment

• Top-up tax payable under the IIR, DMTT, and UTPR must be paid by no later than the end of the GloBE Fiscal Year.

H. Post-Filing Adjustment

• Adjustments to the Covered Taxes are generally recognized in the GloBE Fiscal Year in which the adjustment is made.
  • where the adjustment increases Covered Taxes, the increase is recognized in the current year.
  • where the adjustment decreases Covered Taxes, the taxpayer may be required to recalculate the ETR and top-up tax under the Additional Current Top-Up Tax mechanism.
• However, where the decrease in Covered Taxes is less than EUR 1 million on an aggregated jurisdictional basis (immaterial), taxpayers may elect to recognize the adjustment in the current year without recalculating prior GloBE computations.

I. Audit and Dispute Resolution

• The ITA may conduct monitorings and audits on GloBE compliance, while taxpayers may seek dispute resolution through objections, appeals, or lawsuits.

J. Transitional Simplified Reporting Framework

• Additionally, PER-6/PJ/2026 also introduces a Transitional Simplified Reporting Framework for GIR reporting, allowing an FCE to report on a simplified jurisdictional basis where:
  • no top-up tax arises; or
  • top-up tax is not required to be allocated to individual CE.
• Under this framework, financial accounting adjustments may be reported on an aggregated jurisdictional basis instead of an entity-by-entity basis.
• The simplified reporting framework applies to GloBE Imposition Years beginning on or before 31 December 2028 and ending no later than 30 June 2030. Nevertheless, the ITA may still request additional or entity-level information where necessary.

K. Safe Harbour under PER-6/PJ/2026

• PER-6/PJ/2026 also regulates additional administrative and reporting requirements relating to Safe Harbour within the GIR framework, with further details provided in its attachments.
• Under the GIR framework, the FCE must disclose jurisdictions applying Safe Harbour or de minimis exclusions resulting in a nil/zero top-up tax position.
• The regulation recognizes several Safe Harbour mechanisms, including:
  • Permanent Safe Harbour;
  • Transitional Country-by-Country Reporting (CbCR) Safe Harbour;
  • Transitional UTPR Safe Harbour; and
  • Qualified Domestic Minimum Top-up Tax (QDMTT) Safe Harbour.
• Taxpayers applying Safe Harbour are also required to disclose the relevant basis used, such as:
  • de minimis test;
  • routine profits test; or
  • simplified ETR test.
• PER-6/PJ/2026 further introduces simplified jurisdictional reporting and special reporting treatment for jurisdictions applying QDMTT Safe Harbour.