Tax Audit MoF Reg. Revised to Curb DGT‘s Defeat in Disputes

“We expect that audit outcomes, despite any lawsuit in the objection or the Tax Court, will lead to a higher success rate. Currently, the DGT's win rate at the lawsuit level is less than 50%,” said Andri in a webinar held by the Indonesian Association of Tax Practitioners and Professionals (Perkumpulan Praktisi dan Profesi Konsultan Pajak Indonesia/P3KPI in Indonesian) on Wednesday (19/3/2025).

The risk of tax disputes will be mitigated through two measures, i.e., an entry meeting after the submission of the notice of tax audit and discussion of temporary findings before the notice of tax audit findings (SPHP).

In the entry meeting, tax auditors are required to explain the rationale and objectives of the audit as well as inform the rights and obligations of the taxpayer during and after the audit.

“The entry meeting may be conducted either online of offline. If held online, the official report will be submitted to the taxpayer and must be signed within five business days,” stated Andri.

However, please note that the entry meeting is not held in the case of specific audits. For such audits, the reasons, objectives, rights and obligations of the audited taxpayer are notified in writing at the time the notice of tax audit is submitted.

The discussion of temporary findings refers to a discussion between a taxpayer and tax auditors on temporary audit findings, the results of which are outlined in the official report. This procedure is essential to ensure that the findings are based on robust evidence and aligned with statutory laws and regulations in the field of taxation.

“The goal is for tax auditors to obtain relevant and sufficient evidence related to tax audit corrections. The discussion of temporary findings is aimed to allow tax auditors to obtain sufficient and relevant documents or evidence,” Andri added.

Andri elaborated that in practice, prior to the issuance of MoF Reg. 15/2025, tax auditors had organised discussions of temporary findings with taxpayers. MoF Reg. 15/2025 simply formalises these stages.

Promulgated and declared effective from 14 February 2025, MoF Reg. 15/2025, repeals and declares the invalidity of several former regulations, namely MoF Reg. 17/2013 as amended by MoF Reg. 184/2015, MoF Reg. 256/2014 and Article 105 of MoF Reg. 18/2021. (sap)