PBB‑P5L Objection Not Subject to Administrative Fine

Jakarta, 4 December 2025 – The Ministry of Finance clarified that objections to the Tax Due Notice (SPPT) or Tax Determination Letter (SKP) for PBB‑P5L are not subject to administrative fines. PBB‑P5L refers to land and building tax on plantations, forestry, oil‑gas, geothermal, mineral and coal mining sectors. The rule applies when the objection is rejected or only partially granted.

This differs from the general provisions of the General Provisions and Tax Procedures Law (KUP), where objections to other taxes that are rejected or partially granted may incur a 30 % or 60 % penalty depending on the dispute stage. Article 20 paragraphs 4 and 5 of PMK 118/2024 expressly exclude SPPT and SKP for PBB‑P5L, including cases where the taxpayer files an appeal or a tax court review. Consequently, no administrative fine is imposed during those procedures.

The exemption reduces additional costs for taxpayers dealing with PBB‑P5L when contesting assessments. Taxpayers of other tax types must still account for possible penalties under the KUP. The regulation aims to provide clearer legal certainty for affected sectors.