The Supreme Court has issued Regulation (PERMA) Number 3 of 2025 concerning Guidelines for the Handling of Criminal Cases in the Field of Taxation, to provide comprehensive and uniform guidance for judges in handling tax crime cases. The goal is to eliminate inconsistent legal interpretations and ensure a more effective recovery of state revenue losses.

Key highlights are as follows:

• Broad Legal Subjects
  Criminal tax liability applies to “Every Person,” encompassing both individuals and corporations, regardless of whether they are registered as Taxpayers.
• Corporate Accountability
  A corporation’s criminal liability is not terminated by the resignation or death of its management members.
• Bankruptcy and Dissolution
  Ongoing or completed bankruptcy and dissolution processes do not eliminate the criminal liability of management, controlling personnel, or other parties for crimes committed when the offense occurred.
• Examination of Preliminary Evidence (Bukti Permulaan “Bukper”)
  The Bukper stage is officially equated with the investigation (penyelidikan) stage under criminal procedural law. Furthermore, all activities within the Bukper stage are explicitly excluded from the scope of pretrial (praperadilan) review.
• Asset Seizure and Blocking
  Investigators are authorized to block assets for evidentiary purposes or recovery of state losses. Seizure of a suspect’s assets—including bank accounts and securities—is permitted to facilitate the recovery of state revenue.
• Tax Payment Incentives
  Payments of tax principal and administrative sanctions made by the defendant will be considered by judges when determining the length of imprisonment and the amount of fines.
• Leniency Provisions
  For individual defendants who settle their tax obligations before a judgment is rendered, the judge may find them guilty without imposing a prison sentence, although a fine will still be applied based on the payments already made.

This regulation came into effect on its promulgation date, 23 December 2025.