PER-6/PJ/2026: Indonesia’s Administrative Framework for Global Minimum Tax Is Now in Force

The OECD/G20 Pillar Two framework has been operational in Indonesia since 1 January 2025, when the Income Inclusion Rule (IIR) took effect under PMK No. 136 of 2024. The Undertaxed Profits Rule (UTPR) followed on 1 January 2026. What was missing until recently was the administrative layer: the specific procedures for registration, the standardized forms for filing, the payment codes, and the supervision mechanisms that tell a multinational enterprise group exactly how to comply, not just that it must.

PER-6/PJ/2026 fills that gap. Issued by Director General of Taxes Bimo Wijayanto and effective 4 May 2026, the regulation operationalizes Indonesia’s GloBE compliance framework across eight chapters and 32 articles. For MNE groups with Indonesian constituent entities, this regulation converts a substantive tax obligation into a set of concrete administrative deadlines, form specifications, and payment procedures. The question of whether an MNE group is in scope was answered by PMK 136/2024. The question of precisely what to do and by when is now answered by PER-6/PJ/2026.

Who Is in Scope: The EUR 750 Million Threshold

The scope of GloBE in Indonesia, confirmed in Article 3 of PER-6/PJ/2026, covers Constituent Entities of MNE Groups that are domiciled or established in Indonesia, where the group’s consolidated annual gross revenue reaches at least EUR 750 million. That threshold must have been met in at least two of the four fiscal years preceding the GloBE Fiscal Year.

The 15 percent minimum effective tax rate applies at the jurisdictional level. Where an Indonesian Constituent Entity’s effective tax rate falls below that floor, a top-up tax is imposed through one of three mechanisms:

• Income Inclusion Rule (IIR): Applied at the level of the Ultimate Parent Entity (UPE), requiring the parent to pay additional tax to bring the group’s effective rate up to 15 percent in each low-tax jurisdiction.
• Undertaxed Profits Rule (UTPR): A backstop mechanism that applies where IIR has not been fully implemented or where the top-up tax has not been fully collected at the parent level. Under PMK 136/2024, UTPR became applicable in Indonesia from 1 January 2026.
• Domestic Minimum Top-up Tax (DMTT): Applied directly to Indonesian Constituent Entities whose effective tax rate falls below 15 percent. The DMTT is specifically relevant for companies holding Indonesian tax incentives, including tax holidays and tax allowances, that reduce their effective rate below the global minimum.

The interaction between DMTT and Indonesia’s tax incentive regime is the point most relevant for large foreign investors who have structured their Indonesia presence around pioneer industry incentives. A company holding a 100 percent Corporate Income Tax reduction under the tax holiday scheme and paying no Indonesian corporate tax does not escape the minimum tax obligation if it is part of an MNE group above the EUR 750 million threshold. The DMTT ensures Indonesia collects the top-up tax domestically, rather than allowing the parent’s home jurisdiction to collect it under IIR. The detailed interaction between the tax holiday structure and the GloBE top-up mechanism, including why the DMTT position is generally preferable to home-country IIR collection for the group’s overall effective rate, is covered in the strategic guide to obtaining a tax holiday in Indonesia.

For MNE groups that have not yet formally assessed whether their Indonesian operations cross into GloBE scope, the Permanent Establishment risk analysis that often accompanies this assessment is addressed in the guide to Permanent Establishment risk for foreign companies in Indonesia, which covers the PMK 112/2025 framework that tightened PE determination from 1 January 2026, creating direct interaction with GloBE obligations for some groups.

The Registration Obligation: Nine Months, No Grace for Inaction

Article 4 of PER-6/PJ/2026 establishes the registration deadline: Constituent Entities meeting the GloBE criteria must submit an application to add GloBE taxpayer status through the DJP Portal Wajib Pajak (Coretax) no later than nine months after the end of their first GloBE Fiscal Year.

For MNE groups whose GloBE Fiscal Year aligns with the calendar year, the first GloBE Fiscal Year was 2025. The filing deadline for SPT Tahunan PPh GloBE for that year was four months after year-end, placing the first annual GloBE return deadline at 30 April 2026. That deadline has already passed as of the date of this publication. Groups that have not yet filed for the 2025 GloBE Fiscal Year are already in a late-filing position and should seek specific advice on remediation. The registration deadline, however, remains open: nine months after the first GloBE Fiscal Year ends means 30 September 2026 for calendar-year groups, and this is the more immediately actionable deadline for groups that have not yet completed their GloBE taxpayer status registration.

There is a specific risk in the PER-6/PJ/2026 framework for groups that delay or overlook registration: Article 4 expressly authorizes the Head of the Tax Office to determine GloBE taxpayer status ex officio based on administrative research or exchange-of-information data. Failure to register does not protect an in-scope entity from GloBE obligations. It simply removes the group’s ability to control the timing and framing of the registration process, and potentially exposes it to administrative enforcement from a position of non-compliance.

Three Reporting Obligations, Three Different Deadlines

Once registered, a GloBE taxpayer in Indonesia must fulfill three separate reporting obligations, each with its own form type, deadline, and submission mechanics.

Annual GloBE Income Tax Returns (SPT Tahunan PPh GloBE)

Article 7 requires GloBE taxpayers to submit an Annual GloBE Income Tax Return package consisting of up to three components depending on the entity’s position within the MNE group:

• SPT Tahunan PPh GloBE: Filed by the Ultimate Parent Entity (UPE) and covers IIR obligations
• SPT Tahunan PPh DMTT: Filed by every GloBE taxpayer, regardless of group position
• SPT Tahunan PPh UTPR: Filed by non-UPE entities where UTPR top-up tax has been allocated to them

The filing deadline is four months after the end of the GloBE Tax Year. For the first year, a two-month extension is available. All three returns are electronic documents submitted through the Coretax portal. The forms require disclosure of jurisdictional effective tax rates, adjusted covered taxes, GloBE income or loss computations, substance-based income exclusions, and top-up tax calculations for each applicable mechanism.

GloBE Information Return (GIR)

The GloBE Information Return is a separate, standardized report that the Ultimate Parent Entity or a designated Reporting Constituent Entity must submit to DJP. Under Article 13, the GIR must be prepared in XML format, following DJP’s prescribed specifications. The filing deadline is 15 months after the end of the GloBE Fiscal Year, extended to 18 months for the first year.

The GIR is designed to align Indonesia’s reporting architecture with the OECD’s standardized GloBE Information Return framework, enabling cross-border exchange of information between tax authorities. For groups that have already filed a GIR with another jurisdiction using the OECD standard format, Indonesia does not require a duplicate full filing: Article 14 allows entities to attach the receipt of the global GIR submission to their Indonesian annual GloBE return, though a local Notification must still be separately submitted.

Notification

Article 14 requires GloBE taxpayers to submit an electronic Notification to DJP identifying the Ultimate Parent Entity, Indonesian Constituent Entities, and the entity designated to file the GIR on behalf of the group. The Notification deadline follows the same timeframe as the GIR under Articles 15(1) and 15(2). The Notification functions as an administrative disclosure mechanism rather than a full tax computation, but its submission is a standalone obligation, not merged with any of the three annual returns.

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Payment: Three Mechanisms, Three Payment Codes

Top-up tax payments are due no later than the end of the GloBE Tax Year, which for calendar-year groups means 31 December of the relevant year. All additional tax is paid under tax account code 411618, but with separate payment type codes (Kode Jenis Setoran or KJS) for each mechanism:

• KJS 610 for additional tax under IIR
• KJS 620 for additional tax under UTPR
• KJS 630 for additional tax under DMTT

The separation of payment codes has a compliance consequence that is worth flagging explicitly. Remittance under the wrong KJS does not automatically count toward the obligation under the correct mechanism. A payment coded 610 (IIR) does not offset a DMTT liability coded 630, and the misclassification can trigger an additional tax assessment with interest for late payment on the correct obligation, even if the total amount paid was sufficient to cover both. Groups relying on treasury teams unfamiliar with this structure need to build the KJS verification step into their payment workflow before the first remittance is made.

Post-Filing Adjustments and DJP Supervision

PER-6/PJ/2026 does not close the compliance cycle at filing. Article 21 introduces the Additional Current Top-Up Tax mechanism: if a material decrease in taxes paid exceeding EUR 1 million is identified after a GloBE return has been filed, a recalculation is required, and the additional liability must be reported and paid. This post-filing adjustment obligation runs parallel to DJP’s own audit authority under Articles 23 and 24, which authorize DJP to conduct research, request explanations, and initiate examinations of GloBE obligations across all entities in scope.

For MNE groups whose Indonesian entities are among several jurisdictions filing coordinated GloBE returns, the Indonesian local compliance position must be consistent with the group-level GIR and any positions taken in other jurisdictions. The Coretax infrastructure underpinning PER-6/PJ/2026’s submission and payment framework is the same system through which DJP conducts automated data matching across tax filings. Inconsistencies between the GloBE return data and existing corporate income tax filings, transfer pricing documentation, and LKPM investment reports are the most likely triggers for a DJP inquiry under Article 23.

The annual income tax compliance calendar that underpins GloBE obligations for Indonesian Constituent Entities runs alongside, not instead of, the standard Indonesian corporate tax obligations. The interaction between the GloBE SPT filings and the regular SPT Tahunan PPh Badan is addressed as part of the annual tax reporting compliance framework for companies in Indonesia, which covers the sequencing and filing architecture that in-scope groups need to manage in parallel.

What In-Scope MNE Groups Need to Do Now

For MNE groups with Indonesian Constituent Entities that have not yet taken action under the GloBE framework, the priority sequence is:

• Confirm scope: Verify whether the group’s consolidated revenue in at least two of the four fiscal years preceding the current GloBE year met the EUR 750 million threshold. If yes, GloBE obligations apply regardless of whether registration has been initiated.
• Register through Coretax: Submit the GloBE taxpayer status application through the DJP Portal Wajib Pajak before the nine-month deadline. For calendar-year 2025 first-year groups, the registration deadline is 30 September 2026.
• Assess DMTT position: Calculate the effective tax rate of Indonesian Constituent Entities under GloBE rules. Any entity with ETR below 15 percent faces a DMTT liability, and every GloBE taxpayer must file the SPT Tahunan PPh DMTT regardless of whether DMTT is actually owed.
• Prepare GIR in XML format: Identify who within the group structure is responsible for preparing and submitting the GIR to DJP, and confirm the XML format specifications against DJP’s annexes to PER-6/PJ/2026 (Lampiran A through J).
• Structure the payment workflow: Ensure treasury procedures specify the correct KJS code for each payment type, and verify that the payment deadline (end of GloBE Tax Year) is tracked separately from the SPT filing deadline.

XPND’s tax compliance and international tax advisory team supports MNE groups with Indonesian Constituent Entities through the GloBE registration process, DMTT effective tax rate analysis, and SPT filing preparation under PER-6/PJ/2026.

Reach out to XPND’s tax team to assess your group’s GloBE registration status and compliance position before the September 2026 registration deadline closes.