Global Minimum Tax in Indonesia: PMK 136/2024 and PER-6/PJ/2026

Indonesia has adopted the OECD's global minimum tax (Pillar Two, also called the GloBE rules) for very large multinational groups. It matters mainly to groups with a subsidiary, branch or investment in Indonesia, but foreign investors should know whether their group is in scope.

Who is in scope

PMK 136/2024 applies to corporate taxpayers that are part of a multinational group with consolidated global revenue of at least EUR 750 million, and it taxes at a minimum effective rate of 15%. The IIR and the DMTT apply from tax year 2025, while the UTPR applies from tax year 2026 ^[3][5]. An owner-managed PT PMA or the Indonesian business of an individual expatriate is almost never in scope. A subsidiary of a large group is.

The three mechanisms

PMK 136/2024 sets out the substantive rules, including ^[1][3]:

• Income inclusion rule (IIR): the parent entity pays top-up tax on low-taxed profits of group members.
• Undertaxed profits rule (UTPR): a backstop that denies deductions or requires an equivalent adjustment where profits are low-taxed and not already captured.
• Domestic minimum top-up tax (DMTT): Indonesia charges the top-up tax itself on Indonesian group entities whose effective rate is below 15%, so that the revenue stays in Indonesia ^[3].

The effective tax rate is calculated on a jurisdictional basis using GloBE income and covered taxes, not simply the rate shown in the local tax return.

What PER-6/PJ/2026 adds

The Directorate General of Taxes issued regulation PER-6/PJ/2026 on 4 May 2026. It does not replace PMK 136/2024. It operationalises it through procedures on registration of GloBE taxpayers, filing and electronic submission, the annual GloBE tax return, the GloBE Information Return (GIR), notifications, payment of top-up tax, adjustments after reporting and enforcement ^[1][4]. It has 24 articles and ten attachments (Appendices A to J) with forms and instructions ^[4]. It also includes a transitional simplified reporting framework for eligible taxpayers, which RSM describes as running to 2030 and not a safe harbour from audit ^[2].

Key deadlines reported by advisers

According to RSM's reading of the regulation ^[2]:

• Registration as a GloBE taxpayer is due within nine months after the end of the first application year. For a calendar-year group starting in 2025, that is 30 September 2026.
• The GIR, in OECD XML format, is due 18 months after the application year ends, which is 30 June 2027 for year-end 2025.
• Top-up tax must be paid by the end of the fiscal year that follows the GloBE tax year, for example by 31 December 2026 for fiscal year 2025 ^[5].

Groups with non-calendar financial years should recompute these dates rather than copy them, and should read the official text.

Why it matters even if you are not in scope

Local entities of large groups are often asked by head office for data. Smaller foreign investors who plan a future listing, merger or sale to a large group should expect due-diligence questions about effective tax rates. Tax incentives, such as holidays, can lead to a top-up tax if the group is in scope.

Practical advice

1. Confirm with group tax whether the Indonesian entity belongs to an in-scope group and who is the filing entity.
2. Check whether registration was completed on time, and agree who is responsible for the GIR.
3. Map Indonesian incentives and low-tax outcomes, since they may now be offset by top-up tax.
4. Align the local financial statement data and tax provisions with the GloBE calculation.
5. Keep the work papers that support the calculation, because the transitional reporting regime is not an audit safe harbour ^[2].

Sources

1. KPMG, Indonesia administrative guidelines under Pillar Two (PER-6/PJ/2026)
2. RSM Indonesia client alert, 17 June 2026
3. Pajak.com, scope and main points of PMK 136/2024
4. International Tax Review, Indonesia introduces administrative framework for global minimum tax
5. MUC Consulting, Understanding UTPR in PMK 136/2024