PMK 15/2025 Tightens Tax Audits and Transfer Pricing Oversight

Indonesia’s Ministry of Finance issued Ministerial Regulation No.15/2025 on Tax Examinations on 14 February 2025. The rule introduces three audit types—comprehensive, focused, and specific—to improve efficiency and fairness in tax audits. It aims to provide legal certainty for taxpayers.

PMK 15/2025 replaces earlier provisions such as PMK 17/2013 and sets strict audit time limits of five, three, and one month respectively. It eliminates the questionnaire, adds a Term of Reference for focused audits, and allows interim findings to be discussed, facilitating electronic cross‑border document verification. These changes particularly target transfer‑pricing issues that have been a major challenge.

For multinational corporations, tighter deadlines and clearer scope are expected to shorten audit duration and enhance tax certainty. The regulation’s impact will depend on consistent field implementation and international cooperation. Authorities hope the measure will close gaps in intra‑group pricing manipulation and strengthen tax system fairness.