Indonesia’s Directorate General of Taxes (DJP) has issued Regulation No. PER-6/PJ/2026, establishing detailed procedures for compliance with Pillar Two global minimum tax rules, including registration, reporting, and payment obligations for affected multinational enterprise groups.
Indonesia’s Directorate General of Taxes (DJP) issued Regulation No. PER-6/PJ/2026 on 4 May 2026, setting out procedures for complying with Pillar Two global minimum tax obligations under Regulation No. 136 of 2024.
PER-6/PJ/2026 establishes comprehensive regulations for global minimum tax administration in Indonesia through 13 chapters. This regulation targets Multinational Enterprise Groups with annual revenues of at least EUR 750 million, requiring them to adhere to the Global Anti-Base Erosion (GloBE) rules. It outlines specific procedures for taxpayer registration, data modification, and the mandatory filing of Global Information Returns (GIR) and specialised tax returns. The regulation also defines key mechanisms such as the Income Inclusion Rule (IIR) and the Domestic Minimum Top-up Tax (DMTT) to ensure a minimum effective tax rate of 15%.
Furthermore, it clarifies the protocols for tax payments, audits, and legal appeals available to affected entities. By formalising these international tax standards, the regulation provides a structured path for compliance with global tax transparency agreements.
The regulation also provides detailed filing requirements for three types of annual income tax returns: the GloBE Annual Return, the Domestic Minimum Top-up Tax (DMTT) Return for collecting additional taxes domestically, and the Undertaxed Payment Rules (UTPR) Return for situations where profits are taxed below the minimum rate. The regulation also establishes procedures for submitting the GloBE Information Return (GIR), which facilitates information exchange between tax jurisdictions.
Key provisions of the regulation include:
Tax subject (GloBE Taxpayer)
These rules apply to Multinational Enterprise (MNE) Groups with a total annual consolidated revenue of at least EUR 750,000,000. This threshold must be met in at least two of the four years immediately preceding the tax year.
Taxation mechanism
A top-up tax is imposed if the Effective Tax Rate of an MNE Group in a jurisdiction is less than the 15% minimum tax rate. This is implemented through three main instruments:
- Income Inclusion Rule (IIR): Imposes a top-up tax on the Parent Entity regarding undertaxed constituent entities.
- Undertaxed Payment Rules (UTPR): Acts as a backstop to impose top-up tax when the IIR has not been fully applied.
- Domestic Minimum Top-up Tax (DMTT): A domestic top-up tax imposed on Indonesian entities whose effective tax rate is below the minimum.
Reporting obligations
GloBE Taxpayers must submit several types of documents through the Taxpayer Portal:
- Annual GloBE Income Tax Return: This includes the GloBE Return, DMTT Return, and/or UTPR Return. The deadline for submission is four months after the end of the tax year.
- GloBE Information Return (GIR): Detailed technical information regarding the application of GloBE, submitted in digital (XML) format. It is due no later than 15 months after the end of the tax year (extended to 18 months for the first year).
- Notification: A written notice regarding the identity of the reporting entity is required for those not submitting the GIR directly.
Tax payment
Top-up taxes (IIR, DMTT, and UTPR) must be paid and settled by the end of the GloBE Tax Year using specific tax account and deposit codes. Reports may be filed in Indonesian Rupiah or the currency used in the Consolidated Financial Statements. Furthermore, a Transitional Simplified Reporting Framework is available for tax years starting on or before 31 December 2028.
Earlier, Indonesia’s Ministry of Finance introduced Regulation No. 136 of 2024, implementing Pillar Two global minimum tax rules in the country. The rules apply to multinational enterprise (MNE) groups with annual consolidated revenue of at least EUR 750 million in at least two of the previous four years, and cover the Income Inclusion Rule (IIR), Qualified Domestic Minimum Top-up Tax (QDMTT) effective from 1 January 2025, and the Undertaxed Payment/Profit Rule (UTPR) effective from 1 January 2026.
