On 14 February 2025, the Minister of Finance  introduced the new Regulation No. 15 of 2025 (PMK-15), updating Indonesia’s Tax Audit Procedures. While retaining some of the provisions in the previous regulations, i.e. PMK-17/2013, PMK-184/2015, PMK-256/2014, and PMK-18/2021, PMK-15 introduces key refinements to enhance clarity and efficiency.

Salient changes in PMK-15 are as follows:

1. PMK-15 classifies tax audits into three distinct categories along with their respective timelines as per the table below:

Notes:

• Closing and reporting period is 30 working days at the maximum;
• For group taxpayers and transfer pricing audits, the testing period may be extended by up to four months (previously six months); and
• For Focused Tax Audits, the tax auditor is required to issue a written notification to the taxpayer specifying the items under examination. 

  2. Taxpayers are now required to submit their written response to the Tax Audit Findings Notification Letter (SPHP) within five working days, down from the previous seven-day deadline, and no extension can be applied. 

   

  3.PMK-15 also mandates a Discussion of Provisional Findings (pra-SPHP) between the auditors and the Taxpayer at least one month before the SPHP issuance. During this stage, the Taxpayer may submit supporting documents, provide explanations, and present witnesses, experts, or third-party representatives.

   

  The Tax Auditors are required to record all discussions, documents submitted, and the Taxpayer’s attendance in official minutes. This additional step allows Taxpayers more time to address findings before the formal SPHP response deadline.

   

  However, please note that in Specific Tax Audits, certain procedures are not applicable, including the obligation to conduct a Discussion of Provisional Findings (Pembahasan Temuan Sementara) and the initial meeting to explain the tax audit objectives, along with the taxpayer’s rights and obligations following the issuance of the Tax Audit Notification Letter (SP2).

   

  4.PMK-15 accommodates the Coretax system for document submission and electronic signatures on audit-related documents. Furthermore, SPHP notifications and taxpayer responses can no longer be delivered via post, courier, or forwarding services, reinforcing the use of digital platforms for compliance.

  These new procedures apply to tax audits initiated from 14 February 2025, as indicated by the issuance of the Tax Audit Notification Letter (SP2). Audits initiated before this date will continue under the previous framework.