Indonesia’s Ministry of Finance has introduced Regulation No. 136 of 2024, implementing Pillar Two global minimum tax rules in the country.
The regulations apply to MNE groups with annual consolidated revenue of at least EUR 750 million in two of the last four years. This includes the income inclusion rule (IIR) and the qualified domestic minimum top-up tax (QDMTT), effective 1 January 2025, and the undertaxed payment/profit rule (UTPR), effective 1 January 2026.
The regulations apply to all domestic and international groups with a parent company or subsidiary in an EU member state. It also proposes implementing a qualified domestic minimum top-up tax (QDMTT) for members of in-scope groups and certain safe harbours.
The Regulation defines key terms, specifies which entities are subject to GloBE rules, explains how to calculate effective tax rates and additional taxes, and details top-up tax mechanisms like the IIR, UTPR, and QDMTT.
It also establishes return and payment requirements. Top-up taxes under IIR, UTPR, or QDMTT for a given year are due by the end of the following year.
