Announcement PENG-1/PAN/2025: Judicial Review Update – New Administrative Rules for the e-Tax Court Era

For taxpayers applying for Judicial Review of Tax Court decisions, there are updated administrative requirements to follow. Announcement No. PENG-1/PAN/2025 introduces these changes to align with the full implementation of the e-Tax Court system. These adjustments are based on Decision of the Clerk of the Supreme Court of the Republic of Indonesia No. 1467A/PAN/HK2.7/SK/XII/2025 dated 1 December 2025.

Key Highlights for Taxpayers

The focus is on standardizing digital formats to ensure a smoother process at the Supreme Court level. Here is a quick look at the new standards:

  • Mandatory DOCX Format: Key documents, including the Judicial Review Memorandum (PK Memorandum) and Contra PK Memorandum, must now be submitted in DOCX format. This officially replaces the previous RTF format requirement;
  • Colored Scans Only: Electronic files submitted in PDF (such as the signed PK Deed and PK Memorandum) must be colored scans of the original documents;
  • Hybrid Submission: Both Applicants and Respondents are still required to submit the physical copies of their PK applications or PK Counter Memorandums alongside the digital files; and
  • Court Decisions: In addition to PDF, Tax Court Decisions must also be provided in DOCX format.

These rules aim to enhance administrative quality and legal certainty throughout the Judicial Review process. Please note that while earlier provisions from Decision No. 01/PP/2020 generally remain in effect, this new Announcement takes precedence for these specific formatting updates.

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