Minister of Finance Regulation Number 1 of 2026 concerning Fourth Amendment to Minister of Finance Regulation Number 81 of 2024 concerning Tax Provisions for the Implementation of the Core Tax Administration System (including Customs)

Minister of Finance Regulation Number 1 of 2026 is the fourth amendment to PMK Number 81 of 2024, which regulates tax provisions in the context of the implementation of the Core System of Tax Administration. This change is basically made to adjust tax policy to practical needs, especially in order to support the restructuring of business entities, including State-Owned Enterprises, as well as to improve stipulations that previously did not fully accommodate the dynamics of transactions and tax administration in the Coretax system.

One of the main emphases in PMK-1/2026 is the reaffirmation of the regulation regarding the use of book value for the transfer and acquisition of assets in the context of business mergers, consolidations, expansions, or takeovers. In principle, the transfer of assets still uses market value, but taxpayers are given the opportunity to use book value as long as they obtain the approval of the Director General of Taxes. This stipulation provides legal certainty as well as flexibility for taxpayers that restructure their businesses so as not to directly cause burdensome tax consequences, as long as they meet the set requirements.

PMK-1/2026 also emphasizes various definitions and administrative provisions related to the implementation of tax rights and obligations in the electronic system. The entire process, from registration, reporting, and payment to the handling of objections, corrections, and tax refunds, is increasingly centralized through the Tax Administration Core System. With this approach, tax data, including those related to customs and taxes in the context of imports, becomes more integrated, well-documented, and easily traceable by authorities and taxpayers.

In terms of supervision, this change reflects a shift in the approach to tax administration towards data-based and risk-based management. Administrative order, reporting consistency, and conformity between the data submitted and the actual transaction conditions are important factors in assessing compliance. With increasingly integrated systems, data mismatches between tax reports, customs documents, and/or payments will be easier to detect and potentially lead to follow-up checks or corrections.

Overall, PMK-1/2026 affirms the government’s commitment to improve the implementation of Coretax as the backbone of national tax administration. This change is not only technical, but also strategic, as it aims to create a simpler, more transparent, and accountable tax system, while providing legal certainty for compliant taxpayers. For business actors, this regulation emphasizes the importance of internal system readiness, data quality, and administrative compliance so that business processes continue to run smoothly within the framework of an increasingly digitized tax system.