Directorate General of Taxes Records Thousands of Multinational Corporate Groups Within Global Minimum Tax Scope Ahead of Compliance Deadlines

Jakarta, CNN Indonesia — The Directorate General of Taxes (DJP) under the Indonesian Ministry of Finance has reported that thousands of corporate entities belonging to nearly two thousand multinational groups have been identified as falling within the regulatory scope of the Global Minimum Tax (GMT) framework. The announcement highlights Indonesia’s ongoing efforts to align its domestic fiscal architecture with sweeping international tax reforms designed to curb profit shifting and create a more equitable global economic playing field.

According to data released by the tax authority, a total of 22,662 individual taxpayers organized across 1,980 corporate groups were officially tracked within the GMT framework as of October 20, 2026. However, despite the substantial footprint of these multinational entities operating within the Indonesian jurisdiction, compliance remains an ongoing process. Director General of Taxes Bimo Wijayanto noted that only 5,757 taxpayers—representing approximately 25 percent of the total identified universe—have successfully fulfilled their regulatory and administrative compliance requirements thus far.

The disclosure was made during a formal dissemination and socialization event titled "Reduction of Administrative Sanctions and Global Minimum Tax" held at the DJP Head Office in South Jakarta. The forum was organized to assist corporate taxpayers in navigating the complex compliance landscape introduced by international tax harmonization agreements.

Understanding the Global Minimum Tax Framework and Its Origins

The implementation of the Global Minimum Tax is part of a monumental cooperative effort spearheaded by the Organisation for Economic Co-operation and Development (OECD) and the G20 economies. Known widely as the Two-Pillar Solution, this international framework was formulated to address the formidable tax challenges arising from the digitalization and globalization of the modern economy.

Pillar One focuses on the reallocation of taxing rights across different jurisdictions, ensuring that large multinational enterprises (MNEs) pay taxes where their consumers and users are located. Pillar Two, meanwhile, introduces the Global Minimum Tax, which establishes a floor for corporate taxation worldwide.

For decades, aggressive tax competition and corporate tax avoidance strategies—collectively referred to as Base Erosion and Profit Shifting (BEPS)—have allowed multinational groups to shift profits from high-tax countries to low-tax jurisdictions or tax havens. This practice has severely eroded the domestic tax bases of developing and developed nations alike. The GMT framework seeks to neutralize these incentives by ensuring that large corporate groups are subject to an effective tax rate of at least 15 percent, regardless of where they operate or where their profits are ultimately recorded.

Under the international standard, the GMT primarily targets MNEs with a consolidated annual revenue of at least 750 million euros in at least two of the four fiscal years immediately preceding the tested year. When a corporate group’s effective tax rate (ETR) in a specific jurisdiction falls below the 15 percent threshold, a top-up tax is triggered to bridge the deficit.

Three Pillars of Implementation in Indonesia

Indonesia’s adoption of the Global Minimum Tax is anchored in a comprehensive domestic legal framework designed to give effect to the OECD’s Pillar Two guidelines. The regulatory architecture is primarily governed by Minister of Finance Regulation (PMK) Number 136 of 2024, which establishes the foundational rules for domestic minimum top-up taxation and income inclusion. This was followed by Director General of Taxes Regulation Number PER-6/PJ/2026, which outlines the detailed operational procedures for fulfilling tax obligations, managing taxpayer status, reporting, and remitting top-up taxes.

The implementation of the GMT in Indonesia relies on three primary mechanisms:

1. Qualified Domestic Minimum Top-up Tax (QDMTT): This mechanism grants Indonesia the sovereign right to levy a top-up tax on domestic profits that are taxed at an effective rate below the 15 percent minimum. By prioritizing the QDMTT, Indonesia ensures that the primary right to tax locally generated profits remains with the host country where the economic activities and value creation actually take place.
2. Income Inclusion Rule (IIR): The IIR empowers the parent entity of a multinational group to pay a top-up tax on the low-taxed profits of its subsidiary entities located in foreign jurisdictions where the effective tax rate is below 15 percent.
3. Undertaxed Profits Rule (UTPR): Serving as a backstop mechanism, the UTPR applies adjustments—such as the denial of deductions—to entities within a multinational group to capture any residual top-up tax that is not addressed under the IIR.

The rollout of these mechanisms follows a phased timeline. The QDMTT and IIR officially took effect on January 1, 2025, while the UTPR became operational at the beginning of 2026.

Compliance Challenges and Institutional Guidance

During the outreach event in South Jakarta, Director General Bimo Wijayanto emphasized that preparing for the Global Minimum Tax is a complex undertaking that requires meticulous cross-border coordination, detailed data consolidation, and a profound understanding of intricate statutory provisions. Because the calculation of the effective tax rate under GMT rules diverges significantly from standard statutory corporate income tax (PPh badan) calculations, corporations cannot rely on conventional compliance metrics alone.

"We recognize that preparation undeniably requires detailed coordination and a comprehensive understanding of the applicable provisions," Bimo stated. He urged corporate groups to proactively review their consolidated financial statements, verify their statutory status, and collaborate closely with affiliated entities within their corporate networks to reconcile financial data well ahead of statutory deadlines.

Tax authorities have placed special emphasis on upcoming compliance milestones. For multinational groups operating on a calendar fiscal year, the tax period for 2025 carries general payment and reporting deadlines concluding on December 31, 2026. With the compliance window narrowing, the DJP has intensified efforts to guide businesses through the administrative transition, encouraging them to address any potential tax shortfalls before enforcement actions or administrative penalties apply.

Broader Implications for Indonesia’s Investment Climate and Fiscal Sovereignty

The successful integration of the Global Minimum Tax into Indonesia’s fiscal system carries profound implications for the nation’s macroeconomic stability, revenue mobilization, and competitive positioning. For years, developing nations have engaged in aggressive tax incentives—such as tax holidays and tax allowances—to attract foreign direct investment (FDI). While these incentives have successfully drawn multinational capital, they have frequently triggered a "race to the bottom," eroding national revenues without necessarily generating sustainable long-term economic spillovers.

By participating in the Global Minimum Tax framework, Indonesia joins more than 140 jurisdictions in committing to multilateral tax cooperation. Analysts point out that the GMT effectively neutralizes the tax-arbitrage advantage of traditional tax havens. If an Indonesian subsidiary is granted a preferential tax rate that drops its effective tax rate below 15 percent, the home country of the parent company—or Indonesia itself via the QDMTT—can step in to collect the difference. Consequently, the financial benefit of shifting profits offshore is largely neutralized, removing the rationale for such corporate maneuvers.

Furthermore, the implementation of the QDMTT ensures that Indonesia protects its tax base. Rather than allowing foreign jurisdictions to collect top-up taxes on profits generated within Indonesian borders, the domestic mechanism allows the state to capture these revenues directly. These additional receipts can subsequently be channeled into public infrastructure, human capital development, and structural economic enhancements that improve the nation’s baseline investment climate.

Despite these advantages, financial analysts and tax practitioners have noted that compliance costs for large enterprises will rise significantly. Multinational groups must invest heavily in specialized accounting software, legal counseling, and cross-border tax advisory services to ensure accurate calculations under the complex rules of the OECD administrative guidance.

As the December 31, 2026 deadline approaches for calendar-year taxpayers, the Directorate General of Taxes remains focused on expanding outreach and technical support. The primary objective for the remainder of the compliance cycle is to elevate the current 25 percent compliance rate, ensuring that all qualifying multinational enterprises operating within the archipelago successfully meet their international and domestic tax obligations without disrupting broader economic growth.