Advance Refund of Tax Overpayment (Pengembalian Pendahuluan)
An advance refund of tax overpayment is the disbursement of overpaid tax to the taxpayer through formal review (penelitian) rather than full audit (pemeriksaan). This mechanism provides a fast track for taxpayers meeting specific criteria or requirements as set out in Articles 17C and 17D of the General Tax Provisions Law (UU KUP), and Article 9(4c) of the VAT Law (UU PPN). The technical procedure is governed by PMK 28 of 2026, effective 1 May 2026, which revokes a chain of earlier regulations from PMK 39/2018 through PMK 119/2024. After disbursement, the Directorate General of Taxes retains the right to conduct an audit for substantive verification. If a shortfall is found, an Assessment of Underpayment (SKPKB) and penalties will be issued.
This article is for education, not tax advice.
Example
PT Cahaya Ekspor is a PKP with exports making up 90 percent of total supplies. PT Cahaya qualifies as a low-risk PKP and applies for an advance refund of its IDR 600 million April 2026 VAT overpayment. DJP runs a formal review of document completeness, then disburses the funds to PT Cahaya account without requiring a prior audit.
Source: PMK 28/2026, UU KUP Articles 17C and 17D, UU PPN Article 9(4c)
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