Beware of New Taxes for Multinational Groups! Mandatory Reporting and Payment Under Director General of Taxes Regulation Number PER-6/PJ/2026

Introduction

On 4 May 2026, the Directorate General of Taxes issued Director General of Taxes Regulation Number PER-6/PJ/2026 on Procedures for the Exercise of Rights and Fulfilment of Global Minimum Tax Obligations Based on International Agreements (“DGT Regulation 6/2026”), which took effect on the same date. This regulation establishes an operational framework and administrative procedures that bind multinational enterprises in carrying out global minimum tax reporting and payment obligations in Indonesia.

DGT Regulation 6/2026 implements the mandate of Article 65 paragraph (15) of Minister of Finance Regulation Number 136 of 2024 on the Imposition of Global Minimum Tax Based on International Agreements. The Government seeks to prevent tax base erosion and profit shifting practices frequently utilised by Multinational Enterprise Groups (MNE Groups). Through this instrument, the Government imposes additional tax (top-up tax) to ensure that such multinational enterprises contribute taxes at a rate aligned with the global minimum tax rate.

 

Key Provisions

Criteria and Registration Obligations for GloBE Taxpayers

Pursuant to Article 3, a Constituent Entity officially becomes a GloBE Taxpayer if the group’s annual consolidated gross revenue reaches at least EUR 750,000,000 (seven hundred fifty million Euros) in at least 2 of the previous 4 years before the GloBE Fiscal Year. Referring to Article 4 paragraphs (1) and (2), taxpayers meeting these criteria are required to submit an application for status addition no later than 9 months after the end of the first GloBE Fiscal Year. Taxpayers must complete this procedure electronically through the Taxpayer Portal facility. If the taxpayer fails to fulfil this obligation, the Head of the Tax Office is authorised to determine the status addition ex officio.

Deadlines and Mechanism for Filing the Annual GloBE Income Tax Return

Based on Article 7 paragraphs (1) and (3), GloBE Taxpayers are required to submit Annual Income Tax Return documents in the implementation of GloBE, which include the Annual GloBE Income Tax Return, the Annual DMTT Income Tax Return, and/or the Annual UTPR Income Tax Return. Under Article 11 paragraph (1), taxpayers must complete this reporting no later than 4 months after the end of the GloBE Tax Year. However, Article 11 paragraph (2) grants an extension facility of up to 2 months specifically for the first year. Taxpayers intending to utilise this extension facility must attach proof of payment for any outstanding tax payable.

Obligation to Submit GIR and Electronic Notifications

Article 12 paragraph (1) requires the Ultimate Parent Entity of an MNE Group to submit a GloBE Information Return (GIR) to the Director General of Taxes. This mandatory document must be prepared in XML (extensible markup language) format. The deadline for GIR submission is stipulated under Article 13 paragraphs (1) and (2), namely no later than 15 months after the end of the GloBE Fiscal Year, or 18 months specifically for the first year. In addition to the GIR, Article 14 paragraph (1) requires GloBE Taxpayers to submit electronic Notifications. The submission deadline for Notifications follows the same timeframe as the GIR submission pursuant to Article 15 paragraphs (1) and (2). Taxpayers are required to use the receipt of GIR or Notification submission as an attachment when filing the Annual GloBE Income Tax Return.

Procedures for Payment and Remittance of Additional Tax

Article 20 paragraph (1) affirms that all additional taxes payable under the IIR, DMTT, and UTPR schemes must be fully paid no later than the end of the GloBE Tax Year. To facilitate state financial administration, GloBE Taxpayers are required to use tax account code 411618 when paying such additional taxes. More specifically, Article 20 paragraph (4) differentiates the payment type codes, namely code 610 for IIR tax, code 620 for UTPR tax, and code 630 for DMTT tax.

 

Transitional Provisions

Pursuant to Article 30 paragraph (1), Reporting Constituent Entities are entitled to apply the simplified jurisdictional reporting framework mechanism in submitting their GIR reports for countries or jurisdictions that do not generate additional tax obligations, or where additional tax obligations exist but do not need to be allocated to each Constituent Entity. This simplified facility applies to GloBE Fiscal Years commencing on or before 31 December 2028 and will expire for GloBE Fiscal Years ending after 30 June 2030.

 

Closing

DGT Regulation 6/2026 prevents tax base erosion by requiring Multinational Enterprise Groups (MNE Groups) with consolidated revenue of at least EUR 750 million to pay additional tax (top-up tax) in accordance with global minimum standards. This regulation requires taxpayer compliance, starting from the obligation to register the status no later than 9 months after the first Fiscal Year, settlement of additional taxes (IIR, DMTT, UTPR) by the end of the Tax Year, and periodic reporting obligations that include the GloBE Income Tax Return (within a maximum of 4 months) as well as submission of the GloBE Information Return (GIR) in XML format and electronic Notifications (within a maximum of 15 months). Overall, this regulation binds multinational enterprises to procedures for calculation, reporting, and remittance, including a transitional simplified reporting period until mid-2030, in order to establish a more equitable and integrated international taxation system.