Country review · INDONESIA

Indonesia: international tax & transfer pricing.

Research briefing · not legal advice.

Information current to 27 September 20265 min readSource language: English

Indonesia International Tax and Transfer Pricing Review

Information current to: 27 September 2026
Currency and tax year: Indonesian rupiah (IDR); the calendar year is the usual tax year, subject to the taxpayer's approved accounting period.

Executive summary

Indonesia's corporate income-tax framework is based on the Income Tax Law (UU PPh), with the official 2023 consolidated text incorporating amendments through Law No. 6 of 2023. The country materials identify a 22% corporate income-tax rate, a 20% domestic withholding rate on non-resident income under Article 26 (subject to treaty relief), and a 4:1 debt-to-equity thin-capitalisation ratio. The transfer-pricing framework is consolidated in Ministry of Finance Regulation PMK 172/2023. For current work, the analyst should also account for PP 20/2026, which the local source card identifies as an amendment to PP 55/2022, and verify its specific effect on the transaction or period under review.

1. Legal framework and scope

The main sources are the Income Tax Law (UU PPh), the consolidated statutory text (SDSN) incorporating amendments through UU 6/2023, implementing Government Regulations and Ministry of Finance regulations. The local archive also contains PP 20/2026 as a later amendment to PP 55/2022. The materials identify a 22% general corporate income-tax rate. A foreign investor's Indonesian activities may be taxed through an Indonesian company or a permanent establishment, known locally as a BUT. The law also includes controlled foreign company rules, foreign tax credits, interest limitations and anti-avoidance provisions. UU PPh Articles 2, 18, 24 and 26 are key provisions for BUT status, transfer pricing and CFC rules, foreign tax credits and non-resident withholding. Confirm the applicable implementing regulation and effective date for each issue; PP 20/2026 should be read together with the underlying PP 55/2022 provisions it amends.

2. Permanent establishment and taxable nexus

The Income Tax Law recognises a BUT, or permanent establishment. Review fixed premises, construction or installation activity, personnel and dependent agents, contract authority, service activity and the duration and substance of the Indonesian presence. A treaty may restrict Indonesia's domestic taxing right. If a BUT exists, assess registration, profit attribution, deductible expenses and filing obligations. A foreign company should track local functions, decision-making, contract activity and project days so that the tax position matches actual operations.

3. Withholding tax and cross border payments

Payment to a non-residentDomestic position in source packTreaty and practical point
DividendsArticle 26 domestic rate generally 20%A treaty may reduce the rate; confirm recipient status, beneficial ownership and required documents.
InterestArticle 26 domestic rate generally 20%Check treaty article, instrument terms, recipient and any gross-up clause.
RoyaltiesArticle 26 domestic rate generally 20%Test domestic and treaty definitions, especially for software and know-how.
Services and other incomeArticle 26 may apply at 20% depending on income classificationDetermine source, place of activity, treaty treatment and any BUT connection before payment.
Branch profit remittance20% branch profit tax noted in the dossierCheck the relevant treaty and statutory relief or reinvestment conditions.

4. Royalties software and services

For software, SaaS, cloud hosting, data access and technical support, identify exactly what the customer may do and what the supplier must deliver. A licence of copyright or know-how may be treated differently from standard software access, hosting, implementation, maintenance or a service performed in Indonesia. Keep the agreement, work records, acceptance evidence, rights schedule and payment allocation. Apply Article 26 only after identifying the income category, source rule, treaty position and whether the activity is connected with a BUT.

5. Treaties and double tax relief

Treaty relief should be reviewed before payment. Confirm the treaty in force for the period, the recipient's residence, beneficial ownership and anti-abuse conditions, and the procedural documents required for the payer to apply a reduced rate or for the recipient to claim a refund. Article 24 provides for foreign tax credit relief. The materials also identify CFC rules and deemed-dividend treatment. Maintain foreign tax certificates and a reconciliation of foreign income, credit claimed and Indonesian taxable income.

6. Transfer pricing

PMK 172/2023 is the current standalone transfer-pricing regulation in the local archive and applies from the 2024 tax year. It establishes the arm's-length principle (PKKU), associated-party analysis, method selection, secondary adjustments, transfer-pricing documentation, APA and MAP procedures. It replaces the earlier PMK 213/2016, 49/2019 and 22/2020 identified in the source card. The listed methods include comparable uncontrolled price/transaction (CUP/CUT), resale price, cost plus, TNMM and profit split. Select and apply the method using the transaction facts, functional analysis, comparability and reliable data. Review intragroup services, financing, guarantees, intangibles, commodities and business restructurings. A secondary adjustment may be treated as a dividend and may create Article 26 withholding exposure. The regulation requires transfer-pricing documentation, including master-file, local-file and country-by-country reporting where applicable, and supports controlled-transaction reporting and advance pricing agreements. Build a calendar for documentation preparation and filing, align contracts with actual conduct, and preserve the benefit and allocation evidence for services. Confirm specific thresholds, due dates, language and penalties in PMK 172/2023 and current DGT procedures before filing.

7. Priority actions

Sources reviewed