PER-10/PJ/2025, New Procedures For Tax Information Exchange

Tax News Flash
New Regulation Update: PER-10/PJ/2025
Consolidated Procedures for Exchange of Tax Information
Issued: 22 May 2025 | Effective: 22 May 2025

The Directorate General of Taxes (DGT) has issued PER-10/PJ/2025, an implementation regulation of Minister of Finance Regulation No. PMK 39/PMK.03/2017, consolidating and modernizing Indonesia's procedures for the Exchange of Information (EOI) under international tax agreements. This regulation formally revokes four previous regulations: PER-67/PJ/2009, PER-28/PJ/2017, PER-24/PJ/2018 and PER-02/PJ/2022 and establishes a unified legal basis for all types of tax information exchange and associated administrative cooperation instruments.

Key Highlights of PER-10/PJ/2025

1. Unified legal framework for all exchange types

The regulation brings together three types of information exchange into a single legal instrument with standardized procedures and definitions:

• Exchange of Information on Request (EOIR): Allows DGT to request or respond to specific information inquiries with partner jurisdictions
• Spontaneous Exchange of Information (SEOI): Enables DGT to proactively send or receive relevant tax data without a formal request, typically when risks are identified.
• Automatic Exchange of Information (AEOI): Facilitates regular, systematic exchange of tax-related information, including income, withholding and financial data.

These frameworks, previously regulated under separate rules, are now governed in a single, harmonized instrument.¹

These exchange formats, previously scattered across PER-67/PJ/2009, PER-28/PJ/2017 and PER-24/PJ/2018, are now integrated with consistent definitions and unified administrative procedures.

2. Broader definition and source of tax information

The regulation clearly defines the categories and sources of information eligible for exchange:

• Taxpayer identity and beneficial ownership
• Accounting, banking and tax records
• Cross-border transactions and domestic law changes
• Withholding tax and other financial data
• Third-party sources, including government bodies and financial institutions²

Compared to previous rules, the new regulation explicitly includes broader data sources and categories, such as financial account access and regulatory updates, thereby enhancing transparency.

3. Codification of administrative cooperation Instruments

PER-10/PJ/2025 formally includes cross-border cooperation tools:

• Competent Authority Meetings (CAMs) for treaty interpretation and coordination
• Tax examinations abroad where DGT officials may participate in or observe foreign audits and vice versa
• Simultaneous tax examinations of related taxpayers across countries³
  
  These instruments were previously governed under PER-02/PJ/2022 and are now explicitly embedded in the broader exchange regime, with clearer triggers and procedures for use.
  

4. Secure transmission and mandatory system integration

All exchanged data must be securely transmitted via encrypted platforms, email or verified courier and mandatory logging in DGT's Coretax or other integrated systems:⁴

These system integration and traceability obligations were not formalized in previous rules. Their inclusion reinforces audit trails and supports automation readiness.

5. Enhanced confidentiality and data usage controls

The regulation enforces strict rules on how exchanged information may be used and safeguarded:

• Tax-only use limitation, with no disclosure for non-tax purposes
• Internal security procedures for handling, storing and monitoring exchanged data
• Retention of usability, even after-tax decisions or court rulings⁵

Unlike older rules, PER-10/PJ/2025 embeds confidentiality obligations and internal governance protocols into binding procedures for DGT units.

6. Centralized authority and delegation

The regulation clarifies that the Director General of Taxes holds the authority to conduct exchanges and may delegate this to senior officials (i.e., Delegation to Directors or Echelon II officials in charge of international tax).⁶

This administrative structure supports timely and accountable exchanges, enhancing Indonesia's responsiveness to international requests.

7. Formal revocation of previous rules

PER-10/PJ/2025 officially revokes the following outdated regulations:

• PER-67/PJ/2009
• PER-28/PJ/2017
• PER-24/PJ/2018
• PER-02/PJ/2022⁷

These revocations streamline the legal landscape, removing overlap and ambiguity around EOI implementation.

A&M Insight

PER-10/PJ/2025 signals Indonesia's continued commitment to international tax cooperation. It reflects a strategic shift by the DGT toward a digitally integrated, standardized and enforceable EOI system. For multinational groups and financial institutions, this elevates expectations for cross-border compliance and information consistency. Considering PER-10/PJ/2025's expanded scope and integration of exchange procedures, multinational taxpayers and reporting institutions are encouraged to take the following steps:

1. Map cross-border tax exposure
   Proactively identify jurisdictions with which Indonesia has active information exchange relationships whether under EOIR, SEOI or AEOI frameworks to assess potential areas of disclosure and scrutiny.
   
2. Ensure consistency of global reporting positions
   Reconcile Indonesian tax returns and documentation with foreign filings and disclosures, particularly where financial accounts, beneficial ownership or intercompany transactions are involved.
   
   As an example, we are aware that the DGT sometimes requests information from the Revenue Authority of Singapore (IRAS) to clarify discrepancies between the ID tax return and the consolidated financial statements filed in Singapore. The un-reconciled figures are likely to lead to a tax dispute between the taxpayer and the DGT in the future.
   
3. Strengthen internal documentation and audit preparedness
   Enhance your recordkeeping to support potential data requests, joint tax examinations, or spontaneous information sharing. This includes maintaining robust transfer pricing files, ownership documentation and legal structuring justifications.
   
4. Monitor regulatory and treaty developments
   Track Indonesia's evolving tax treaty network and administrative agreements to anticipate new reporting obligations or risk areas under expanded information exchange protocols.

Footnotes

1 Articles 3–6 of PER-10/PJ/2025, https://perpajakan.ddtc.co.id/sumber-hukum/peraturan-pusat/peraturan-direktur-jenderal-pajak-per-10pj2025?bahasa=english

2 Articles 2(2), 4(2)(a-d), 5(2)(a-b), 6(2-4) of PER-10/PJ/2025

3 Articles 7–9 of PER-10/PJ/2025

4 Articles 3(4 & 7) of PER-10/PJ/2025

5 Articles 10(1,3) and 11(2) of PER-10/PJ/2025

6 Article 12 of PER-10/PJ/2025

7 Article 13 of PER-10/PJ/2025

Originally published 18 June 2025

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.