Tax Judge Highlights New Tripartite Model for Digital Economy

Jakarta, 7 November 2025 – Tax Court Judge Junaidi Eko Widodo said the rise of the digital economy will create a tripartite tax relationship, adding marketplaces as a third party alongside taxpayers and the fiscal authority. This model differs from the traditional two‑party framework.

Under Indonesian tax law, the relationship has historically been between the taxpayer and the tax authority. The Tax Procedures Law (Law No. 28/2007) introduces a third actor, the Electronic System Marketplace Operator (PPMSE), appointed to collect, remit and report tax.

If affirmed, marketplaces would acquire taxpayer status with comparable rights and duties, including audit and objection rights. This could increase administrative burdens for e‑commerce operators while expanding the digital tax base. Regulators are expected to issue detailed rules to provide legal certainty.