Summary
Advance refund of tax overpayment is a fast track refund granted without going through an audit. PMK 28/2026, effective 1 May 2026, restructures the rules into three access tracks with one common processing mechanism: review of the taxpayer's application. Applications are now filed through Coretax. This guide walks through each track, processing windows, and how to file.
What Is an Advance Tax Refund
An advance refund is a refund of tax overpayment granted to a taxpayer under Article 17C or 17D of the KUP Law, or Article 9(4c) of the VAT Law. Unlike a standard refund that must go through a full audit, an advance refund is processed through a review: the DGT examines the formal completeness and correctness of the application data without opening a full audit. The output is a Decision Letter on Advance Refund of Tax Overpayment, known as SKPPKP.
Legal Basis
The advance refund framework rests on several complementary regulations:
- Article 17C of Law No. 28 of 2007 on General Provisions and Tax Procedures governs the Qualified Taxpayer category.
- Article 17D of the KUP Law governs the Specific Requirements Taxpayer category.
- Article 9(4c) of Law No. 42 of 2009 on the Third Amendment to the VAT Law governs the Low Risk VAT-Registered Entrepreneur (PKP) category.
- Minister of Finance Regulation (PMK) No. 28 of 2026 on Procedures for Advance Refund of Tax Overpayment is the technical implementing rule, effective 1 May 2026, replacing PMK 39/PMK.03/2018 as last amended by PMK 119/2024.
The primary laws set out when a taxpayer is entitled to apply, while PMK 28/2026 governs the technical procedure and Coretax integration.
Three Advance Refund Tracks
1. Qualified Taxpayer (Article 17C KUP Law)
Under Article 4 of PMK 28/2026, four conditions apply: timely filing of tax returns for all tax types over the past three years; no late payment beyond the final payment deadline for any tax type, including installments and deferrals, within the five years preceding designation; financial statements audited by a public accountant or government financial oversight institution with an unqualified opinion (WTP) for three consecutive years; and no tax arrears, except arrears covered by an installment or deferral permit. Designation applications are filed via Coretax no later than 10 January of the running year.
2. Specific Requirements Taxpayer (Article 17D KUP Law)
This track does not require a separate designation. The taxpayer simply ticks the advance refund box on the overpaid tax return. Eligible categories include individual employees with overpaid Income Tax; non-employee individuals with overpayment up to a set threshold; companies with overpayment up to a set threshold; and PKPs with VAT overpayment up to a set threshold, all as specified in PMK 28/2026.
3. Low Risk PKP (Article 9(4c) VAT Law)
Low Risk PKP includes public companies listed on the Indonesia Stock Exchange, state-owned and regional-owned enterprises, customs main partners, Authorized Economic Operators (AEO), manufacturers, certified large pharmaceutical distributors, certified medical device distributors, and BUMN subsidiaries directly held above 50%. Main condition: at least 80% of the value of supplies is exports or supplies to VAT collectors.
Review Mechanism and Processing Windows
Advance refunds are processed through a review rather than an audit. SKPPKP issuance windows differ across tracks:
- Qualified Taxpayer (Art. 17C): three months for Income Tax, one month for VAT, counted from the date the complete application is received.
- Specific Requirements Taxpayer (Art. 17D): fifteen working days for individual employees, one month for non-employee individuals, one month for companies, one month for VAT, counted from the date the complete application is received.
- Low Risk PKP (Art. 9(4c) VAT Law): one month for VAT from the date the complete application is received.
If the deadline passes without a DGT decision, the application is deemed approved and the SKPPKP is issued ex officio.
How to File via Coretax
Steps to apply for Qualified Taxpayer status in Coretax: (1) log in to the Coretax taxpayer portal; (2) open the Taxpayer Service module; (3) select the Administration Services menu; (4) click the Create Administration Service Request submenu; (5) select sub-service AS.09-01 LA.09-01 Designation of Qualified Taxpayer; (6) upload supporting documents including the last three years of audited financial statements and other items per the form guidance; (7) submit and wait for a decision within a maximum of 30 working days.
For Article 17D and Low Risk PKP, applications are filed together with the overpaid tax return by ticking the advance refund column. Attach supporting documents in Coretax based on the tax type and period.
Worked Example
PT Maju Lestari is a manufacturing company with consolidated revenue of IDR 800 billion in tax year 2025. From 2023 to 2025 the company filed all tax returns on time, never paid any tax late, and received unqualified audit opinions from a big four affiliated firm for three consecutive years. The 2025 Annual Corporate Income Tax Return shows an overpayment of IDR 4 billion. PT Maju Lestari applies for Qualified Taxpayer status via Coretax on 8 January 2026 and receives the designation on 6 February 2026. On 15 April 2026, the company files an advance refund request for the 2025 corporate Income Tax overpayment. Under PMK 28/2026, the SKPPKP must be issued no later than 15 July 2026 (three months for Income Tax).