Indonesia's Ministry of Finance officially replaced its preliminary tax overpayment refund rules through Regulation PMK Number 28 of 2026 (PMK 28/2026), effective 1 May 2026. This regulation revokes PMK Number 39/PMK.03/2018 and all its subsequent amendments, including PMK Number 119 of 2024.
The fundamental change introduced by PMK 28/2026 is the classification of taxpayers into three distinct groups with different entitlements, as well as the full integration of the application process into the Coretax DJP system.
Three Taxpayer Categories
1. Qualified Taxpayers (Wajib Pajak Kriteria Tertentu)
This group covers taxpayers with a consistent compliance record. Requirements under Article 4 of PMK 28/2026 include: filing annual tax returns (SPT) on time for the past 3 tax years, filing monthly returns for January through November of the last tax year before designation, having no outstanding tax debt, having financial statements audited with an unqualified opinion (WTP) for 3 consecutive years, and not having been convicted of tax-related criminal offenses in the past 5 years.
For this group, the Preliminary Tax Refund Decision Letter (SKPPKP) must be issued within 3 months for income tax (PPh) and 1 month for VAT (PPN), counted from the date the complete application is received (Article 7, PMK 28/2026).
2. Taxpayers Meeting Certain Requirements
This group does not require prior designation and operates on a per-SPT application basis. Criteria under Article 9 of PMK 28/2026 include:
- Individual taxpayers not operating a business or independent profession, with any amount of PPh overpayment
- Individual taxpayers operating a business with PPh overpayments up to Rp100 million
- Corporate taxpayers with turnover up to Rp50 billion and PPh overpayments up to Rp1 billion
- Taxable Entrepreneurs (PKP) with supplies up to Rp4.2 billion and VAT overpayments up to Rp1 billion
3. Low-Risk Taxable Entrepreneurs
The third category includes publicly listed companies, state-owned enterprises (BUMN), regional government-owned enterprises (BUMD), customs main partners, Authorized Economic Operators (AEO), manufacturers, major pharmaceutical distributors, certain medical device distributors, and majority-owned BUMN subsidiaries (Article 15, PMK 28/2026).
Integration with Coretax DJP
A significant change is the mandatory filing through the Coretax DJP system. Taxpayers who previously held qualified taxpayer status under the old rules must resubmit designation applications between 1-10 June 2026 (Article 32, PMK 28/2026). Old designations are void as of the effective date of this regulation.
Key Changes from the Previous Rules
Compared to PMK 39/PMK.03/2018, PMK 28/2026 introduces structural changes:
- SKPPKP timelines are now explicit: 3 months (PPh) and 1 month (PPN) for qualified taxpayers
- Three-category classification replaces the previously less-structured approach
- Full Coretax integration eliminates paper-based manual submissions
- The WTP audit requirement is now a mandatory condition, previously less clearly defined
What Taxpayers Should Do
Taxpayers who have been enjoying preliminary refund facilities should verify whether their status remains valid under PMK 28/2026. Those previously registered as qualified taxpayers under PMK 39/PMK.03/2018 must reapply through the Coretax DJP system.
Applications are submitted through the designated menu in the Coretax DJP application, and DJP will provide a decision within 30 working days from receipt of a complete application (Article 6, PMK 28/2026).