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Indonesia: Administrative guidelines under Pillar Two rules

Guidelines under Minister of Finance Regulation No. 136 of 2024 (PMK-136), which adopted the Pillar Two rules in Indonesia

june 4, 2026

The Directorate General of Taxation (DGT) on May 4, 2026, issued Regulation No. PER-6/PJ/2026, providing detailed administrative guidelines under Minister of Finance Regulation No. 136 of 2024 (PMK-136), which adopted the Pillar Two rules in Indonesia.

While PMK-136 establishes the substantive global minimum tax framework, PER-6 focuses primarily on the administrative and compliance procedures applicable to Indonesian global anti-base erosion (GloBE) taxpayers, including:

  • Registration requirements and procedures for GloBE taxpayers
  • Submission of the GloBE annual tax return
  • Content and structure of the GloBE annual tax return
  • Filing of the GloBE information return (GIR) and related notifications
  • Payment and remittance of top-up tax liabilities
  • Procedures for post-reporting adjustments
  • Compliance monitoring, audit, and dispute resolution mechanisms
  • Transitional simplified reporting framework

Read a June 2026 report prepared by the KPMG member firm in Indonesia

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