Indonesia Formalizes Global Minimum Tax Procedures via PER-6/PJ/2026

The Indonesian Director General of Taxes has officially released PER-6/PJ/2026, establishing the definitive procedural framework for implementing the Global Minimum Tax (GloBE) rules. This regulation serves as the technical cornerstone for PMK 136/2024, aligning Indonesia with the OECD’s Pillar Two initiative. By mandating a 15% minimum effective tax rate (ETR) for large multinational enterprises (MNEs), the regulation ensures that Indonesia effectively secures its taxing rights over domestic profits that might otherwise be subject to top-up taxes in other jurisdictions.

For affected MNE groups—those with consolidated annual revenues exceeding €750 million—the new regulation outlines critical compliance milestones. Businesses are now required to navigate a structured process involving formal registration as "GloBE Taxpayers," timely notifications, and the submission of the Global Information Return (GIR). Furthermore, PER-6/PJ/2026 details the mechanisms for calculating and paying top-up taxes through the Domestic Minimum Top-up Tax (DMTT), Income Inclusion Rule (IIR), and the Undertaxed Payment Rule (UTPR), which becomes fully operational in the 2026 tax year.

As Indonesia transitions into this new era of international tax coordination, PER-6/PJ/2026 provides much-needed clarity on administrative requirements and dispute resolution. Taxpayers must ensure their data systems are robust enough to handle the complex jurisdictional ETR calculations and meet strict electronic filing deadlines via the DGT portal. This regulatory shift emphasizes the importance of strategic tax planning and compliance, marking a significant evolution in how Indonesia manages its tax base within the global digital economy.

How does your organization plan to address the new GIR reporting requirements, are you looking for a deep dive into the specific data points required for the filing?

Please feel free to contact FKNK’s advisor anytime at fajar.budiman@fknk.co.id