PMK 71/2026 amends PMK 118/2024 on corrections, objections, reductions, deletions, and cancellations in taxation. Effective from 2 October 2026, the amendments require an instrument-by-instrument assessment of penalty classification, principal settlement, remedy history, and filing requirements.
- Classify each penalty by its legal basis before selecting a relief route.
- Reconcile payments under the principal-first rule; the aggregate balance does not change simply because its allocation changes.
- Article 27A provides a time-limited discretionary route. Eligibility, procedural history, and the authority’s decision remain decisive.
Read the operative amendments accurately
A restated provision is not necessarily new in every respect. Article I identifies the paragraphs amended, inserts Articles 21A and 27A, and replaces Annex C. Compare those instructions with the original PMK 118/2024 before treating a rule as new.
| Change | Practical significance |
|---|---|
| Article 14(2)(h) | Express reference to information exchange with partner tax authorities; reconcile cross-border explanations with counterparty records. |
| Article 16(5) | The wording changes from sejak to setelah dispatch of the SPUH. The period remains ten working days. |
| New Article 21A | Specifies the instruments within ordinary penalty relief and excludes specified dispute-outcome STP penalties from that route. |
| Article 23(6), (7), (9) | Payments are allocated first to principal and then to penalties. Reconcile principal settlement before filing. |
| New Article 27A | Discretionary relief supporting the national economy, for qualifying applications within two years of commencement. |
| Article 32(2) & Annex C | PBB numbering is corrected while the eligibility wording remains; use the replacement Annex C formats and examples. |
The ten-working-day Article 16(5) period and the maximum of two Article 32 applications already existed. They should be distinguished from the new provisions.
Objection review, evidence, and response periods
Amended Article 14(2)(h) adds an express reference to information exchange for tax purposes. In cross-border and transfer pricing matters, an objection’s factual account should be checked against the documents held by overseas counterparties.
For a taxpayer who does not attend, Article 16(5) now refers to a written response within ten working days after dispatch of the Notification Letter to Attend (SPUH). The number of days is unchanged. Arthadaya’s interpretation is that “after” supports excluding the dispatch date; until practice settles, diary the deadline conservatively.
| Response | Period described in the publication |
|---|---|
| First request for books or information | 15 working days after dispatch of the first request. |
| Second request for books or information | 10 working days after dispatch of the second request. |
| Written response to research findings under Article 16(4) | 10 working days after dispatch of the SPUH. |
Keep evidence of dispatch and receipt, assign an owner to each response, and check any additional information request against the period in the relevant letter under Article 14(6).
The scope and limits of ordinary penalty relief
Article 21A identifies penalties in an SKP, assessment-linked STP, other STP, SKP PBB, and STP PBB within the ordinary framework. PBB administrative fines are addressed through reduction.
The exception in Article 21A(b) concerns STP penalties under KUP Law Articles 25(9), 27(5d), and 27(5f), associated respectively with an adverse objection, appeal, or judicial-review outcome. The publication describes the applicable percentages as 30%, 60%, and 60%. These penalties need a separate route analysis.
Article 23 continues to require the relevant principal to be paid in full and imposes procedural-status and formal conditions. A written application in Indonesian should state the amount sought and reasons, relate to the appropriate instrument, carry an authorised signature, and satisfy the collection-stage restriction. Satisfying one condition does not establish overall eligibility.
Principal-first payment allocation
Amended Article 23(6) applies payments first to principal. Under paragraph (7), an excess is applied to penalties or PBB administrative fines. This replaces the earlier timing-based distinction, under which payments before the application month were allocated proportionately.
One payment. A different allocation.
Principal assessed: 1,000 · Penalty: 200 · Cash paid before the application month: 600
| Item | Original | Amended |
|---|---|---|
| Payment allocated to principal | 500 | 600 |
| Payment allocated to penalty | 100 | 0 |
| Principal remaining | 500 | 400 |
| Penalty remaining before relief | 100 | 200 |
| Aggregate balance before relief | 600 | 600 |
Arthadaya illustration; not an official example. The original principal allocation is 600 × 1,000 / 1,200. No other payments or adjustments are assumed. Cash paid and the aggregate remaining balance are identical. Penalty reduction or deletion still requires the relevant decision.
For an actual application, reconcile the specific instrument and payment history. The revised allocation can reduce the further principal payment needed before filing, without itself cancelling a penalty.
Article 27A: a defined window, a discretionary decision
New Article 27A permits the Director General of Taxes to reduce or delete administrative penalties, or reduce PBB administrative fines, to support the national economy. It covers qualifying SKP, SKP PBB, STP, and STP PBB applications meeting Article 23 requirements and filed no later than two years from commencement on 2 October 2026.
The possible reach to dispute-outcome penalties requires care.
Article 27A refers to STP and Article 23 without repeating the Article 21A(b) exception. Arthadaya reads this as supporting possible consideration of dispute-outcome STP penalties during the window. This is an interpretation of the text, rather than an assured outcome. Implementing guidance or DGT practice may take a narrower view.
The provision prescribes no universal relief percentage and no automatic approval. The authority may grant relief, and the collection-stage restriction continues to apply. Prepare well before the October 2028 end of the window, checking the applicable calculation and submission requirements.
- Identify principal and penalty components and the legal basis of each instrument.
- Test the Article 21A classification and the proposed Article 27A route.
- Reconcile principal settlement under the amended allocation rule.
- Map prior remedies and state the amount sought, reasons, and supporting evidence.
One procedural choice can affect another remedy
Article 32 governs reduction or cancellation of an incorrect SKP, SPPT, or SKP PBB. PMK 71/2026 corrects PBB subitem numbering in Article 32(2), while retaining the eligibility wording. The status of earlier remedies remains important.
| Objection against the relevant incorrect SKP | Consequence described in the publication |
|---|---|
| Not filed | The Article 32(2)(a) status condition is met. Other requirements still apply. |
| Filed but not considered | The Article 32(2)(a) status condition is met. Other requirements still apply. |
| Filed and decided | The Article 32(2)(a) condition is not met. |
| Filed and withdrawn with approval | Article 32(3) bars the incorrect-assessment application. |
“Not considered” differs from a substantive rejection. Penalty-relief, audit-procedure cancellation, and PBB-reduction histories also have their own conditions. Review the full Article 32 framework before withdrawing an objection.
The existing maximum of two applications remains. A second application is generally due within three months of dispatch of the first decision, subject to the exception for circumstances beyond the taxpayer’s control. Formal requirements and the remaining status conditions continue to apply.
Transitional treatment and a complete filing record
The specific transitional preservation rule applies to specified STP penalties under KUP Law Articles 25(9), 27(5d), and 27(5f), where the application was received before 2 October 2026 and no decision had been issued at commencement. Those applications are resolved under the original PMK 118/2024. This does not preserve the original treatment for every pending application.
Annex C is replaced, covering formats and calculation examples C.1–C.9. Annexes A, B, and D are marked unchanged. Distinguish taxpayer application forms from authority-side documents; they are not all filing attachments.
Assessment or collection instrument, legal basis, payments, and an instrument-level reconciliation.
Applications, receipt dates, withdrawal approvals, decisions, and evidence for the transitional test.
Amount sought, reasons, signatory authority, supporting documents, current format, and submission channel.
These records connect the amended framework with the continuing conditions. The appropriate remedy depends on both the instrument and its procedural history.
Sources & further reading
Arthadaya The Brief, Tax — 21 October 2026 (public PDF edition)PMK 71/2026 — JDIH Ministry of FinancePMK 118/2024 — JDIH Ministry of FinanceContinue the conversation.
Ramos Pardamean Purbaramos.purba@arthadaya.coAlief Rizky Shibghotullahalief.rizky@arthadaya.coTasya Amanda Putritasya@arthadayapartners.comWebsite adaptation of the dated Arthadaya publication. References to legislation reflect that edition; subsequent rules and developments should be checked. This perspective provides general information and does not constitute legal or tax advice. The facts and applicable requirements need to be assessed for each arrangement.
