PMK 37/2025: Marketplace Platforms Now Collect Income Tax on Behalf of Domestic Sellers

Indonesia’s e-commerce market generated approximately Rp487 trillion in transaction value in 2024, according to BPS and DJP data. Of the estimated 1.6 million UMKM-category taxpayers active in that market, only around 653,000 filed and paid income tax that year. That gap, more than 900,000 businesses generating taxable income without contributing to state revenue, is the direct context for PMK No. 37 of 2025.

The regulation does not create a new tax. What it does is change who is responsible for collecting it.

What the Regulation Does

Issued on 11 June 2025 and effective from 14 July 2025, PMK 37/2025 designates marketplace platform operators (Penyelenggara Perdagangan Melalui Sistem Elektronik or PMSE) as appointed collectors of Article 22 Income Tax (PPh Pasal 22) on behalf of domestic sellers using their platforms. The mechanism works as follows: instead of each seller calculating, remitting, and reporting their own income tax independently, the marketplace withholds 0.5 percent of the seller’s gross revenue at the point of payment, remits it to the state treasury each tax period, and reports it to DJP via the Unified Periodic Income Tax Return (SPT Masa PPh Unifikasi).

The 0.5 percent rate is applied to Peredaran Bruto, defined as the gross transaction value appearing in the billing document, excluding VAT and luxury goods tax. The tax is triggered at the moment payment is received by the marketplace, not at the moment of delivery or invoice issuance.

For sellers already subject to the Final Income Tax regime under PP No. 55 of 2022 (the 0.5% final PPh for taxpayers with annual gross revenue up to Rp4.8 billion), the PPh Pasal 22 withheld by the marketplace counts directly toward settlement of that final tax obligation. If the amount withheld exceeds the final tax due, the seller can apply for a refund of the excess through standard overpayment procedures.

Who Is Affected: The Scope Is Broader Than It Looks

The definition of “Pedagang Dalam Negeri” (Domestic Seller) under Pasal 5 of PMK 37/2025 covers both individuals and legal entities (orang pribadi atau badan) that meet two criteria: they receive payment through a bank or similar financial account, and they transact using an Indonesian IP address or Indonesian phone number. This definition explicitly includes logistics and expedition companies, insurance providers, and other parties facilitating transactions through the platform, not only the primary product sellers.

The practical scope therefore includes:

• Individual sellers (UMKM, resellers, dropshippers) operating through marketplace accounts
• Corporate entities, including PT and CV, selling goods or services through marketplace channels
• Third-party logistics providers and insurers embedded in marketplace transaction flows, as demonstrated in the illustrative examples in the PMK’s Annex

One category of seller that requires specific attention in the PT PMA context: a foreign-owned company (PT PMA) that sells through Indonesian marketplace platforms qualifies as a Pedagang Dalam Negeri under Pasal 5, because the definition refers to legal entities domiciled in Indonesia, not to the nationality of their shareholders. A PT PMA selling products through Tokopedia, Shopee, or any other designated marketplace is subject to the same withholding obligation as a domestically-owned PT.

Exemptions: What Is Not Withheld

Pasal 10 of PMK 37/2025 specifies six categories excluded from the marketplace withholding obligation:

• Individual sellers with annual gross revenue at or below Rp500 million, provided they have submitted the required declaration letter (surat pernyataan) to the marketplace. This threshold applies only to individuals (WP orang pribadi), not to corporate entities.
• Individual delivery drivers who are partners of technology-based transportation application companies (ojek online drivers)
• Sellers holding a tax exemption certificate (Surat Keterangan Bebas or SKB) for withholding
• Sellers of prepaid phone credits and SIM cards
• Sellers of precious metals and gemstones sold by licensed manufacturers and traders
• Sellers of land and building rights, or related binding sale agreements

Two points worth noting on the Rp500 million threshold. First, the exclusion requires the seller to proactively submit the declaration letter to the marketplace before income is received. The exemption is not automatic. Second, once a seller’s cumulative annual gross revenue crosses Rp500 million during the tax year, they must notify the marketplace by the end of that month, after which withholding begins from the first day of the following month.

Obligations for the Marketplace Operator

The compliance burden under PMK 37/2025 sits primarily with the marketplace platform as the designated withholding agent (Pihak Lain). Platform operators must:

• Collect NPWP or NIK, correspondence address, and relevant declarations from all sellers before the first transaction
• Withhold PPh Pasal 22 at 0.5% of gross revenue at the point of payment settlement
• Remit the withheld tax to the state treasury each tax period (by the 15th of the following month, per standard PPh Pasal 22 payment deadlines)
• File the Unified Periodic Income Tax Return (SPT Masa PPh Unifikasi) with all seller transaction information attached (by the 20th of the following month)
• Issue billing documents that function as proof of PPh Pasal 22 withholding for each seller

Failure to comply exposes the platform operator to sanctions under both tax law and the electronic system operator regulations applicable to private sector PMSE operators.

As of July 2026, DJP has formally designated four marketplace platforms as the first appointed withholding agents under PMK 37/2025. Further designations are expected as DJP evaluates additional platforms against the transaction volume and traffic thresholds set under Pasal 3.

Explore Our Services Tax Compliance in Indonesia

What Sellers Need to Do Now

For businesses selling through Indonesian marketplace platforms, the immediate compliance steps are straightforward but time-sensitive.

If your annual gross revenue from marketplace sales is below Rp500 million (individual sellers only): Submit the declaration letter to each marketplace you sell through before the next payment settlement. The marketplace determines the submission format under Pasal 6(8). Without this declaration, the platform will withhold regardless of your actual revenue level.

If your annual gross revenue exceeds Rp500 million, or if you are a corporate entity (PT, CV, or PT PMA): No declaration for exemption is available. PPh Pasal 22 at 0.5% will be withheld automatically. Ensure your tax records account for this prepayment as a creditable amount against your final or periodic income tax obligation, and verify that your annual tax return correctly reflects the cumulative withheld amount.

If you hold a Surat Keterangan Bebas (SKB): Submit a copy to each marketplace operator. The SKB must be renewed per its stated validity period.

For companies that sell across multiple channels simultaneously, including both marketplace and non-marketplace transactions, the PPh Pasal 22 withheld by the marketplace does not affect the withholding obligations that apply to non-marketplace transactions under separate PPh frameworks. The two tracks operate in parallel. Pasal 10(3) of PMK 37/2025 confirms that income already subject to marketplace withholding is not subject to a second round of withholding by other withholding agents for the same transaction.

The interaction between marketplace PPh Pasal 22 withholding and the broader annual income tax compliance calendar, particularly for PT PMA entities managing multiple income streams across marketplace and direct sales channels, is one area where proactive tax position planning reduces year-end reconciliation exposure. For companies that need to assess how PMK 37/2025 fits within their current tax structure, XPND’s tax compliance practice covers the full annual income tax cycle including prepayment credit management and SPT reconciliation.

The Broader Context

PMK 37/2025 is not isolated policy. It sits within a deliberate regulatory trajectory: Indonesia’s tax-to-GDP ratio stood at 10.4 percent in 2024, against a government target of exceeding 13 percent by 2028 as documented in the 2025 KEM-PPKF fiscal policy framework. Broadening the effective taxpayer base in the digital economy, where transaction volumes are large and historical compliance rates have been low, is a structural component of that trajectory.

The mechanism of using platform operators as de facto tax collection agents mirrors approaches used in other markets and is consistent with the broader Coretax data-matching architecture introduced under PMK No. 81 of 2024, which connects digital transaction data to individual and corporate tax identities. Together, these regulations accelerate the integration of digital economic activity into Indonesia’s formal tax administration in ways that make undeclared marketplace income increasingly visible to DJP. For companies managing annual tax reporting and compliance in Indonesia, understanding where marketplace withholding sits in the full tax position is now part of the standard annual planning cycle, not a separate consideration.

Reach out to XPND’s tax compliance team to review how PMK 37/2025 affects your current tax position and whether your marketplace income reporting reflects the new withholding framework correctly.