Tax Audit Assistance in Indonesia, from SP2DK Letters to Tax Court Appeals

Tax audit assistance in Indonesia starts with deadlines. A request for explanation of data (SP2DK) gives you 14 days to respond. A notice of audit findings (SPHP) gives you 5 working days. Deadlines this short leave little time to gather documents and prepare a written response.

Each stage builds on the one before. An SP2DK can lead to an audit, and audit findings become a tax assessment, such as a tax underpayment assessment (SKPKB). An assessment you disagree with moves to objection and appeal, each with its own deadline and penalty risk.

Our role is to keep your position documented at every stage. That means complete files, written responses on time and, where needed, representation before the Tax Court (Pengadilan Pajak).

An SP2DK is a request for explanation of data from your tax office (KPP). Since 1 January 2026, it is governed by Minister of Finance Regulation (PMK) 111 of 2025. You must respond within 14 days, extendable by up to 7 days if the tax office receives your written notice before the deadline.

The letter asks you to explain data or information the tax office holds about your company. The extension must be requested in writing and must arrive within the original 14 days. A request that arrives on day 15 is too late.

If you do not respond on time, the tax office may invite you to a discussion or visit your premises. Supervision can then end in a proposal for a tax audit or a preliminary evidence audit (pemeriksaan bukti permulaan). A complete, documented response within the deadline is the practical way to keep the matter at the supervision stage where possible.

PMK 15 of 2025, in force since 14 February 2025, sets three audit types with maximum testing periods. A full audit allows up to 5 months, a focused audit up to 3 months and a specific audit up to 1 month. Each can add up to 30 working days for the final discussion and reporting.

The regulation replaced the earlier audit rules in PMK 17/PMK.03/2013 and its amendments. The audit type tells you how much time you have to organize documents, answer requests and prepare for discussions with the audit team.

An audit period is not idle time. Auditors request documents, examine books and records, and issue findings that need written responses. A standard restitution claim is also examined through an audit, and our tax restitution service prepares for that from the start.

Source: PMK 15 of 2025, in force since 14 February 2025.

Under PMK 15 of 2025, you respond in writing to the notice of audit findings (SPHP) within 5 working days of receiving it. You are entitled to a final discussion, and to a discussion of interim findings in full and focused audits. Disputes over the legal basis of a correction can go to a Quality Assurance team.

The SPHP window used to be 7 working days, so the current rules leave less time than before. Your response should address each correction, set out your position and attach the supporting evidence.

A request for a Quality Assurance (QA) discussion must be made in writing within 3 working days after the discussion minutes are signed. It is limited to disagreements about the legal basis of a correction. Decide whether you need QA before you sign the minutes, because the window is short.

You can file an objection (keberatan) within 3 months of the date the tax assessment was sent. The Directorate General of Taxes (DGT) must decide within 12 months of receiving the objection, or it is deemed granted. If you disagree with the decision, you can appeal (banding) to the Tax Court within 3 months of receiving it.

The objection rules sit in the General Provisions and Tax Procedures Law (UU KUP), last amended by Law 6 of 2023. Appeals follow the Tax Court Law, Law 14 of 2002. The objection clock runs from the date the assessment was sent, and the appeal clock from the date the decision was received.

Disputes carry a cost if they fail. When an objection is rejected or only partly granted, a 30% administrative penalty may apply. When an appeal is rejected or partly granted, the penalty may be 60%. We weigh these risks with you before anything is filed.

Not every tax consultant can represent a taxpayer before the Tax Court. The attorney license (izin kuasa hukum) is issued by the Chair of the Tax Court, with requirements set by PMK 184/PMK.01/2017. Two Akuntax consultants hold it, so your case can stay with the same team from audit to appeal.

All our consultants hold the tax consultant certification (USKP) and a Ministry of Finance practice license. Read more about our consultants and their credentials.