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
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