2018印度尼西亚税务简报（英文版）

报告摘要

International Tax Indonesia Highlights 2018 Summary

Core Content Overview

This document provides a comprehensive overview of the tax system in Indonesia, covering corporate and personal taxation, as well as value-added tax (VAT) and related compliance requirements. It highlights the key rules, rates, incentives, and anti-avoidance measures applicable to both residents and non-residents in Indonesia.

Corporate Taxation

Residence and Tax Basis

A resident company is one established or domiciled in Indonesia, or with its place of effective management in Indonesia.
Resident companies are taxed on worldwide income, while non-resident companies are taxed only on Indonesian-sourced income, including income from a permanent establishment (PE).

Taxable Income

Taxable income is calculated as assessable income minus tax-deductible expenses.
Assessable income includes business income, gains from property sales, and passive income (e.g., dividends, interest, royalties).

Tax Rates

Standard corporate tax rate: 25%
Reduced rate: 1% for companies with gross income ≤ IDR 4.8 billion
Partial reduction: 50% reduction on taxable income attributable to gross revenue up to IDR 4.8 billion for companies with revenue between IDR 4.8 billion and IDR 50 billion

Tax Incentives

Tax Investment Allowance (TIA): 30% over 6 years
Accelerated depreciation: Available
Extended loss carryforward: Up to 10 years for certain industries
Reduced withholding tax: 10% on dividends paid to non-residents
Tax holiday: Up to 20 years for high-priority sectors, depending on investment and strategic value

Withholding Taxes

Dividends to non-residents: 20% (final tax), reduced under tax treaties
Dividends to residents: 15% (advance tax), exempt under participation exemption
Interest to non-residents: 20% (final tax), reduced under tax treaties
Interest to residents: 15% (advance tax), with some exemptions
Royalties remitted abroad: 20% (final tax), reduced under tax treaties
Royalties paid to residents: 15% (advance tax)
Technical service fees: 2% (advance tax), 20% for remittances abroad
Branch profits tax: 20% on post-tax income of a PE, may be reduced under treaties

Anti-Avoidance Rules

Transfer pricing: Must be on an arm's length basis; documentation required for large transactions
Thin capitalization: Interest is non-deductible if debt-to-equity ratio exceeds 4:1
Controlled foreign companies (CFC): Dividends from foreign subsidiaries are subject to deemed taxation if the Indonesian resident holds ≥50% of shares
Documentation requirements: Three-tiered approach (master file, local file, CbC report) applies to certain taxpayers

Compliance

Tax year: Calendar year, with option to use book year
Filing: Monthly tax returns by 20th of the following month; annual returns within 4 months of book year end
Penalties: 2% monthly interest on underpaid taxes; penalties for late payment and filing
Self-assessment: Required for most corporate taxpayers

Personal Taxation

Residence and Tax Basis

Resident individuals are taxed on worldwide income; non-residents on Indonesian-sourced income
Residency determined by presence in Indonesia for ≥183 days in a 12-month period or intent to reside

Taxable Income

Includes employment income, business profits, capital gains, etc.
Capital gains on shares (listed or unlisted) are taxed as ordinary income

Tax Rates

5% on the first IDR 50 million
15% on income between IDR 50 million and IDR 250 million
25% on income between IDR 250 million and IDR 500 million
30% on income exceeding IDR 500 million

Tax Incentives

A 1% final tax applies to individuals with income ≤ IDR 4.8 billion

Social Security

Resident employees must contribute to manpower scheme (2%–1.74%) and healthcare scheme (4%)
Pension plan is not mandatory for expatriates

Compliance

Tax year: Calendar year
Filing: Annual tax return due by 31 March, extendable by two months
Penalties: 2% monthly interest on underpaid taxes

Value Added Tax (VAT)

Taxable Transactions

VAT applies to delivery of goods and provision of services, including intangible goods and services provided to Indonesian businesses
Certain goods and services are nontaxable

Tax Rates

Standard rate: 10%
Zero-rated: Exports of goods and certain services (e.g., repair, construction)
Luxury Goods Sales Tax (LGST): Rates from 10% to 125% based on product type

Registration

VAT registration required for businesses with annual taxable transactions exceeding IDR 4.8 billion

Filing and Payment

Monthly VAT return due by end of the following month
VAT payment due before the return is filed
Self-assessed VAT on foreign intangible goods/services due by 15th of the following month

Other Taxes

Real property tax: Up to 0.3% of NJOP (estimated market value)
Land and building tax: Up to 5% on acquisition value or NJOP
Stamp duty: IDR 3,000 or 6,000 on certain documents
No inheritance or net wealth tax

Tax Treaties and Laws

Indonesia has 67+ tax treaties
Signed the OECD Multilateral Instrument in 2017
Tax laws include:
- Income Tax Law 7/1983 (as amended)
- VAT Law 8/1983 (as amended)
- General Rules & Procedures of Taxation Law 6/1983 (as amended)