Requirements to Become a Tax Representative and Procedures for the Exercise of Rights and Fulfillment of Tax Obligations by Tax Representatives

The Government has issued Minister of Finance Regulation Number 44 of 2026 (“MoF Reg. 44/2026”) concerning the Requirements to Become a Tax Representative and the Procedures for the Exercise of Rights and Fulfillment of Tax Obligations by Tax Representatives. With the issuance of this regulation, Minister of Finance Regulation Number 229/PMK.03/2014 has been revoked and declared no longer valid. This regulation was issued to implement Article 32 paragraphs (3) and (3A) of the General Tax Provisions and Procedures Law (the “KUP Law“), with the aim of providing greater legal certainty, promoting equal treatment and administrative efficiency, as well as accommodating the Constitutional Court Decision Number 63/PUU-XV/2017.

Key changes introduced under MoF Reg. 44/2026: 

MoF Reg. 44/2026 introduces several significant changes relating to the requirements, appointment, implementation, and termination of tax representation. Accordingly, taxpayers and parties acting as tax representatives should take note of the following key changes:

• The categories of eligible tax representatives have been expanded and are no longer limited to Tax Consultants and employees of the taxpayer.
• Competency requirements are now differentiated based on the category of tax representative appointed.
• Administrative processes have been further digitalized through the introduction of electronic Special Powers of Attorney submitted via the Taxpayer Portal (Coretax).
• The scope of authority under a Special Power of Attorney has been clarified by adopting the principle of one representative for one tax right or obligation, accompanied by a prohibition on the substitution of authority.
• Transitional provisions continue to permit certain parties to use paper-based Special Powers of Attorney until 31 December 2026.

With the issuance of MoF Reg. 44/2026, taxpayers and parties acting as tax representatives should ensure that the appointment and exercise of tax representation comply with the new requirements introduced under this regulation. MoF Reg. 44/2026 became effective on 6 July 2026, the date of its promulgation, while the transitional provisions allow certain parties to continue using paper-based Special Powers of Attorney until 31 December 2026.