Tax Assessment Statute of Limitations
The Tax Assessment Statute of Limitations sets the deadline for DJP to issue an SKP. Under Article 13 of UU KUP, DJP may not issue an SKP more than 5 years after the end of the tax period, partial tax year, or tax year. However, the limitation is extended to 10 years if the taxpayer is proven to have committed a tax crime. After the limitation expires, DJP loses the right to assess or collect tax for that period. The collection statute of limitations is separately regulated under Article 22 of UU KUP at 5 years from SKP issuance or tax debt arising.
This article is for education, not tax advice.
Example
PT Lama filed an incomplete 2018 return. DJP may issue an SKPKB for 2018 no later than 31 December 2023 (5 years). After that, DJP cannot collect any 2018 shortfall.
Source: Articles 13 and 22 UU KUP No. 28/2007
Related terms