Indonesia Global Minimum Tax: Scope, Criteria and Timeline

Indonesia’s Ministry of Finance Regulation No.136/2024 introduces a global minimum tax (GMT) for domestic taxpayers and permanent establishments that are constituent entities of multinational groups with annual revenue of at least EUR750 million. The rule takes effect for the 2025 tax year, and the additional top‑up tax must be paid no later than 31 December 2026.

To be covered, an entity must belong to a group whose consolidated revenue reaches EUR750 million in at least two of the four preceding tax years. Exemptions include government bodies, international organisations, non‑profit entities, pension funds and primary investment funds. Indonesia applies GMT through three mechanisms: the income inclusion rule (IIR) and qualified domestic minimum top‑up tax (QDMTT) from 1 January 2025, and the undertaxed payment rule (UTPR) from 1 January 2026.

The finance authority estimates roughly 5,000 constituent entities will fall under GMT, requiring companies to calculate the additional tax and disclose their GMT status in financial statements under the PSAK 212 amendment. Timely compliance helps avoid penalties and supports fiscal transparency.