COD for Indonesian Resident Taxpayers

On 14 December 2018, the Director General of Taxes (“DGT”) issued regulation Number PER-28/PJ/2018 (“PER-28”) regarding Certificate of Domicile (“COD”) for Indonesian Tax Residents in order to implement Double Taxation Avoidance Agreements (“Tax Treaties”). This regulation revokes Regulation No.PER-08/PJ/2017 (“PER-08’).
To request the issuance of COD, this regulation requires the taxpayer to fulfil certain requirements, as follows:

  • The taxpayer is an Indonesian Tax Resident ;
  • The taxpayer already has a Tax ID number;
  • The taxpayer has submitted the Annual Income Tax Return; and
  • The application has to fulfil the administrative requirements. (Among others: specifically states the counterparty in the treaty partner country, its Tax ID number, and type of income received from the offshore party)

PER-28 is expected to simplify the administrative process in the application and the issuance of the COD by using an electronic system (online). The taxpayer can submit the application online. DGT will check the completeness of the submission electronically and issue the COD electronically through the online system. However, if the electronic system is in error, the application still can be submitted through the tax office (manually).

This regulation limits the validity period of the COD, which is only valid until 31 December of the year of issuance of the COD.

PER-28 will become effective as of 1 February 2019.

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