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      Indonesia’s Directorate General of Taxation (Direktorat Jenderal Pajak, DJP) introduced Regulation Number PER-11/PJ/2025 (PER-11) on 22 May 2025.1  The Regulation significantly broadens the scope and detail of asset disclosure required in the Annual Indonesian Individual Tax Return (SPT) beginning with the 2025 tax year.  

      This Regulation is designed to support the implementation of the Core Tax Administration System and addresses longstanding ambiguities regarding asset reporting.

      Overall, the Regulation aims to strengthen Indonesia’s tax administration and promote transparency, but it requires taxpayers to adopt more rigorous reporting practices and help ensure readiness for the 2025 filing cycle..

      WHY THIS MATTERS

      The expanded asset disclosure requirements under PER-11 represent a fundamental shift in Indonesia’s approach to individual wealth reporting, impacting all taxpayers without exception.  The new rules eliminate previous ambiguities and set a uniform standard for asset declaration, which is expected to improve compliance, reduce under-reporting, and enhance the effectiveness of tax audits.

      Taxpayers must now prepare for increased scrutiny and a higher administrative burden, as the DJP will have greater visibility with respect to both domestic and overseas assets.

      The need to reconcile existing disclosures with the new asset categories and codes may prompt inquiries from tax authorities and necessitate amendments to historical tax returns.  While these changes provide clearer guidance and facilitate more accurate tax reporting, they may require taxpayers to reconcile previous declarations with the new requirements and potentially amend past returns.  Accurate and complete record-keeping becomes crucial, as any discrepancies or omissions could result in compliance risks or penalties.  For taxpayers with complex or international asset portfolios, the expanded requirements may also introduce additional challenges in gathering and reporting the required information.  

      More Details 

      Previously, asset disclosure was limited and subject to individual interpretation, with many taxpayers only reporting assets located within Indonesia and providing summary information for worldwide holdings.  PER-11 now mandates comprehensive reporting of all forms of wealth – tangible and intangible, movable and immovable, and regardless of location.  The Regulation also revises and introduces new asset codes, enhancing transparency and consistency in wealth declaration.

      Comprehensive Asset Categories

      • All Forms of Wealth: Mandatory reporting of tangible/intangible, movable/immovable assets, used for business or personal purposes, located in Indonesia or abroad.
      • Seven Asset Categories: Cash and equivalents, receivables, investments/securities, movable assets, immovable assets, other assets (including intellectual property and collectibles), and asset overview.

      Expanded Information Requirements

      • Cash and Equivalents: Must now include account number, holder’s name, bank name, and asset location.
      • Receivables: Requires borrower’s name, NPWP, location, and currency conversion.
      • Investments/Securities: Asset location, institution name and NPWP, account number, currency conversion, and “fair value” methods.
      • Movable Assets: Vehicle details, registration number, ownership, currency conversion, and fair value methods.
      • Immovable Assets: Location, size, ownership source, certificate number, currency conversion, and fair value methods.
      • Other Assets: Full asset name, weight (for gold), currency conversion, and fair value methods.
      • Liabilities: Now require lender’s NPWP and name, and the creditor country.

      Asset Codes and Valuation

      • Revised and New Codes: Introduction of additional asset codes for more granular classification.
      • Valuation Methods: Detailed fair value reporting, including appraisals, DJP standards, and taxpayer methods.

      Mandatory Application

      All individual taxpayers must comply, regardless of asset type or location.

       

      KPMG INSIGHTS

      Steps to Consider

      In light of the upcoming changes, organisations and individuals within the scope of the Regulation may wish to consider the following:

      • Taxpayers may wish to conduct a thorough review of their asset portfolios, including overseas holdings, so that all required information is available and accurately documented.
      • Entities may wish to update internal record-keeping systems and processes to capture the expanded data fields mandated by PER-11.
      • Individuals may wish to consult with tax advisers to reconcile past asset declarations with the new requirements and determine if amendments to prior returns are necessary.
      • Organisations may wish to educate staff and stakeholders about the new compliance obligations and potential audit risks associated with incomplete or inaccurate reporting.

      What’s Next?

      The expanded asset disclosure regime is likely to result in increased tax authority inquiries and audits, particularly in the initial years of implementation.  As taxpayers and the DJP adapt to the new system, further refinements and clarifications may be issued.  Enhanced cross-border cooperation and information exchange may also become more prominent, further supporting Indonesia’s tax enforcement efforts.

      If assignees and/or their programme managers have any questions or concerns about the scope of the Regulation, its application and potential impacts, and appropriate next steps, they should consult with their qualified tax professional or a member of the GMS tax team with KPMG in Indonesia (see the Contacts section).

      FOOTNOTE:

      1  Direktorat Jenderal Pajak, PER-11/PJ/2025 on Procedures for Withholding, Deposit, and Reporting of Income Tax in the Coretax Administration System, issued on 22 May 2025, Ministry of Finance Legal Documentation and Information Network.  See: https://jdih.kemenkeu.go.id.

      The Regulation can be found at (in Indonesian): https://jdih.kemenkeu.go.id/dok/per-11pj2025.

      RELATED RESOURCE:

      This article is excerpted, with permission, from "Indonesia expands asset disclosure requirements – Is your tax return ready?" in Global Mobility Services Bulletin (August 2025), a publication of the KPMG International member firm in Indonesia.

      Contacts

      esther-kwok
      Esther Kwok

      Partner, Tax

      KPMG in Indonesia

      natalia-yamin
      Natalia Yamin

      Director, GMS

      KPMG in Indonesia

      More Information

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      The information contained in this newsletter was submitted by the KPMG International member firm in Indonesia.

      GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.

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