Summary
Indonesia's Ministry of Finance issued Regulation Number 28 of 2026 (PMK 28/2026) on Procedures for Advance Refund of Tax Overpayment. The regulation took effect on 1 May 2026 and revokes all prior MoF regulations from PMK 39/2018 through PMK 119/2024.
This regulation becomes the single reference for taxpayers seeking accelerated refunds. The Directorate General of Taxes (DJP) confirmed that advance refunds will continue to be processed through formal review (penelitian), not full audit (pemeriksaan), preserving service speed without compromising data validity.
Three Eligible Taxpayer Groups
PMK 28/2026 sets out three advance refund schemes. First, taxpayers meeting specific criteria under Article 17C of the General Tax Provisions Law (UU KUP). Second, taxpayers meeting specific requirements under Article 17D of UU KUP. Third, low-risk Taxable Entrepreneurs (PKP) under Article 9(4c) of the VAT Law (UU PPN).
The Article 17D category covers four subgroups. Individual taxpayers without business or independent profession activities filing an overpaid annual income tax return (SPT Tahunan PPh) form the first subgroup. Individual taxpayers running a business or independent profession with overpayment of up to IDR 100 million form the second. Corporate taxpayers with annual turnover of IDR 0 to IDR 50 billion and overpayment up to IDR 1 billion form the third. PKPs with monthly VAT returns (SPT Masa PPN) showing overpayment of up to IDR 5 billion form the fourth.
New Threshold for Low-Risk PKPs
A notable point is the tightened criteria for low-risk PKPs. A PKP must conduct exports of taxable goods (BKP), supplies of BKP or taxable services (JKP) to VAT collectors, supplies on which VAT is not collected, exports of intangible BKP, or exports of JKP totaling at least 80 percent of total supplies and exports.
The 80 percent threshold signals that the accelerated refund facility targets PKPs whose primary activity is export-oriented or serves VAT collectors. PKPs whose transactions are mostly domestic with regular counterparties must follow the standard refund procedure.
Review, Not Audit
PMK 28/2026 reaffirms the formal review approach for advance refunds. Review focuses on document completeness and formal compliance, while a full audit handles substantive testing that takes longer.
DJP stated it will tighten formal review of refund requests submitted by low-risk PKPs. The reinforcement aims to prevent misuse of the facility and protect state revenue from potential leakage.
Implications for Taxpayers
For individual non-business taxpayers with PPh overpayment, the new mechanism preserves a fast track without audit. For small businesses and mid-size corporate taxpayers, the IDR 100 million and IDR 1 billion ceilings clarify whether they qualify for the accelerated route or must use the regular path.
Exporting PKPs need to review the composition of their supplies. If the share of exports or supplies to VAT collectors falls below 80 percent, low-risk PKP status will not be granted automatically and the refund request will be processed through the standard route.
What Taxpayers Should Do
Taxpayers planning to use the accelerated refund facility should evaluate three things. First, which category fits their profile. Second, whether supporting documents are complete enough to pass formal review. Third, for PKPs, whether the composition of supplies meets the 80 percent threshold set by PMK 28/2026.
DJP is rolling out PMK 28/2026 socialization through official channels. Technical implementation guidance is expected via a Director General of Taxes Regulation (PER-DJP) to detail review procedures and document formats.