Summary
Indonesia's Directorate General of Taxes (DJP) issued Director General Regulation PER-6/PJ/2026 on Procedures for Exercising Rights and Fulfilling Obligations of the Global Minimum Tax. The regulation was set and entered into force on 4 May 2026. PER-6/PJ/2026 implements MoF Regulation 136/2024 that adopted the Global Anti-Base Erosion Rules (GloBE) in Indonesia.
The core message: multinational enterprise groups with consolidated revenue of at least EUR 750 million in 2 of the previous 4 fiscal years must register and report under the global minimum tax framework. Effective rates below 15 percent will trigger top-up tax.
Who Must File
The regulation covers Constituent Entities or Joint Venture Group members of an MNE Group that meet the EUR 750 million threshold. The threshold must be met in at least 2 of the 4 fiscal years preceding the running GloBE tax year.
Qualifying taxpayers must apply to add GloBE Taxpayer status via the electronic taxpayer portal. The submission deadline is no later than 9 months after the end of the first GloBE tax year.
Three Mechanisms
PER-6/PJ/2026 regulates the three core Pillar Two mechanisms:
- Income Inclusion Rule (IIR): charges top-up tax to the parent entity when foreign subsidiary income is taxed at an effective rate below 15 percent.
- Qualified Domestic Minimum Top-up Tax (QDMTT): a domestic top-up tax ensuring the gap to the 15 percent minimum is collected in Indonesia, effective retroactively from 1 January 2025.
- Undertaxed Payment Rule (UTPR): a backstop rule that distributes top-up tax collection to other jurisdictions when IIR does not apply. Effective from 1 January 2026.
The three mechanisms are applied in the sequence set by the OECD/G20 Inclusive Framework on BEPS.
Three New Return Types
DJP introduces three return types for GloBE taxpayers: the Annual GloBE Return, the Domestic Minimum Top-up Tax (DMTT) Return, and the UTPR Return. The Annual GloBE Return must be filed electronically no later than 4 months after the end of the GloBE tax year. For the first year of implementation, taxpayers may request an extension of up to 2 months.
The Ultimate Parent Entity of an MNE Group must also file a GloBE Information Return (GIR). The GIR deadline is 15 months after the end of the GloBE tax year, or 18 months for the first year of implementation.
Implications for Taxpayers
PER-6/PJ/2026 also covers payment, post-filing adjustments, supervision, audit, and dispute procedures. For Indonesia, QDMTT ensures the gap to 15 percent is collected here, rather than diverted to parent jurisdictions through another country's IIR.
MNEs already enjoying tax holidays in Indonesia should reassess the impact. Incentives that bring effective rates well below 15 percent may still trigger top-up tax via QDMTT.
Legal Basis
- MoF Regulation 136/2024 on the Imposition of Global Minimum Tax Based on International Agreements
- PER-6/PJ/2026 on Procedures for Exercising Rights and Fulfilling Obligations of the Global Minimum Tax, Articles 1 to 13
- OECD GloBE Model Rules and Commentary
Sources
DDTCNews, OECDPillars.com, Ortax, Pajakku, cross-checked with DJP publications.