Summary
Notaries and Land Deed Officials (PPAT) in Indonesia face a layered tax structure: professional fee withholding under PPh 21/26, the option to use NPPN norms instead of actual costs, VAT obligations once registered as a Taxable Entrepreneur (PKP), and annual filing via SPT 1770. This guide covers every layer with the applicable regulation and article numbers.
Professional Status Under Indonesian Tax Law
Notaries and PPATs are classified as independent professionals (pekerjaan bebas) under Article 1 number 24 of Law No. 36 of 2008 on Income Tax (UU PPh). They are not employees; their income is subject to PPh 21 withholding when paying clients are institutions or legal entities, and PPh 26 for foreign-national notaries.
PPAT functions are regulated by PP No. 37 of 1998 as amended by PP No. 24 of 2016. Notary functions are regulated by Law No. 2 of 2014 on the Notary Profession.
Key Regulations
- UU No. 36 Tahun 2008 (UU PPh) — Article 21 paragraph (1) letter d: withholding on professional fee payments.
- PMK No. 168/PMK.03/2023 — Article 3: DPP for independent professionals is 50% of gross fee.
- PER-17/PJ/2015 — NPPN (deemed income) norms for notaries, KLU 69100.
- UU No. 42 Tahun 2009 (UU PPN) — Article 4 paragraph (1) letter c: VAT on taxable services.
- PMK No. 197/PMK.03/2013 — PKP registration threshold (IDR 4.8 billion annual revenue).
- UU No. 7 Tahun 2021 (UU HPP) — Article 7: revised PTKP and progressive PPh OP rates.
How Income Tax Is Calculated
PPh 21 Withholding (Institutional Clients)
When a PT, CV, government body, or other legal entity pays a notary or PPAT fee, it must withhold PPh 21.
Under PMK 168/2023 Article 3, the Deemed Tax Base (DPP) is 50% of gross fee. The net DPP is then taxed at the progressive PPh OP rate (Article 17 UU PPh).
Example — fee IDR 10,000,000:
| Step | Amount |
|---|---|
| Gross fee | IDR 10,000,000 |
| DPP (50%) | IDR 5,000,000 |
| PPh 21 withheld (5% tier) | IDR 250,000 |
| Net received | IDR 9,750,000 |
For annual cumulative net income above IDR 60 million, the 15% rate applies on the excess portion.
NPPN Option
Notaries not subject to bookkeeping may elect to use NPPN norms (PER-17/PJ/2015) by notifying the local KPP before March 31 each year. For KLU 69100 (legal and notary activities):
| City Tier | NPPN Rate |
|---|---|
| 10 major cities | 51% of gross revenue |
| Other provincial capitals | 47% |
| Other regions | 43% |
NPPN means the notary's taxable net income = gross revenue x NPPN percentage. No actual expense deduction is allowed when using this method.
Annual PPh OP Rates
| Net Taxable Income | Rate |
|---|---|
| Up to IDR 60,000,000 | 5% |
| IDR 60,000,001 - 250,000,000 | 15% |
| IDR 250,000,001 - 500,000,000 | 25% |
| IDR 500,000,001 - 5,000,000,000 | 30% |
| Above IDR 5,000,000,000 | 35% |
PTKP for a single individual is IDR 54,000,000 per year (UU HPP Article 7).
VAT for Notary and PPAT Services
Notary and PPAT services are Jasa Kena Pajak (JKP) — taxable services under UU PPN Article 4. Once annual revenue exceeds IDR 4.8 billion (PMK 197/2013), registration as PKP is mandatory.
Upon PKP registration:
- Issue Tax Invoice (Faktur Pajak) for each service fee collected.
- VAT rate: 12% of the service fee (effective from January 2025 under PP No. 1 Tahun 2025).
- File SPT Masa PPN monthly via e-Faktur by the end of the following month.
Notaries below the IDR 4.8 billion threshold may register voluntarily. Most solo practitioners do not cross this threshold, but those in high-volume areas (Jakarta, Surabaya) may reach it.
Filing SPT Tahunan (Annual Return)
Notaries and PPATs file SPT 1770 (self-employed / business income form) via DJP Online.
Key deadlines:
- March 31 — deadline for SPT 1770 (individuals)
- March 31 — deadline to elect/renew NPPN option
Documents to prepare:
- Recapitulation of all fees received (per client if possible)
- PPh 21 withholding receipts (Bukti Potong) from institutional clients
- Expense receipts (if using actual cost method)
- PTKP status documentation
Installment PPh 25 payments are made monthly if the annual tax liability from the prior year exceeds withholding credits (PER-22/PJ/2013).
Real-World Example
Notary in Jakarta, annual gross fee IDR 600,000,000, using NPPN:
| Item | Calculation | Amount |
|---|---|---|
| Gross revenue | — | IDR 600,000,000 |
| NPPN (51%) | 600M x 51% | IDR 306,000,000 |
| PTKP (single) | — | IDR 54,000,000 |
| Net PKP | 306M - 54M | IDR 252,000,000 |
| PPh tier 1: 5% x 60M | — | IDR 3,000,000 |
| PPh tier 2: 15% x 192M | — | IDR 28,800,000 |
| Total PPh OP | — | IDR 31,800,000 |
PPh 21 withheld by institutional clients during the year is credited against this amount. If withheld PPh 21 exceeds total liability, the excess is refundable.