TTM 4 - Income Tax Article 22, 23 and 26

COLLECTION WITHHOLDING
Income Tax
• Article 22
• Article 23
• Article 26,
• Article 4(2) and
• Article 15
ENDAH MIRASANTY,
SH,SE.,Ak.,M.Ak.,CA.,BKP
Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP
1. Regulation of the Minister of Finance Number 253/PMK.03/2008 concerning Certain CoIDRorate Taxpayers as Income
Tax Collectors from Buyers on the Sale of Very Luxury Goods
2. Regulation of the Minister of Finance Number 39/PMK.011/2013 concerning Obligations with Withholding and/or Collection of
Income Tax Payable to Other Parties by Companies Bound by Production Sharing Contracts, Contracts of Work, or
Cooperation Agreements on Mining Businesses
3. Regulation of the Minister of Finance Number 90/PMK.03/2015 Concerning Amendments to Regulation Minister of Finance Number
253/PMK.03/2008 Concerning Certain Entity Taxpayers As Income Tax Collectors From Buyers on Sales of Goods Classified as
Very Luxurioun
4. Regulation of the Minister of Finance Number 34/PMK.010/2017 Regarding Collection of Income Tax Article 22 Regarding Payment
5. Regulation of the Minister of Finance Number 110/PMK.010/2018 concerning Amendment to Regulation of the Minister of Finance
Number 34/PMK.010/2017 concerning Collection of Income Tax Article 22 in Relation to Payment For the delivery of goods and
activities in the field of import or business activities in other fields
6. Regulation of the Minister of Finance Number 92/ PMK.03/2019 concerning the Second Amendment to Regulation of the Minister
of Finance Number 253/PMK.03/2008 concerning Taxpayers of Certain Entities as Tax Collectors Income from Buyers on Sales of
Goods Classified as Very Luxurious
7. Regulation of the Minister of Finance of the Republic of Indonesia Number 199/PMK.010/2019 Concerning Provisions Customs,
Excise, and Taxes on Imported Goods
8. Regulation of the Minister of Finance Number 6/PMK.03/2021 Concerning Calculation and Collection of Value Added Tax and
Income Tax on Delivery/Income in Connection with the Sale of Top-Up, Startup Cards, Tokens and Vouchers

9. Regulation of the Director General of Taxes Number PER - 53/PJ/2009 concerning Forms of Periodic Income
Tax Notification Forms Article 4 Paragraph (2), Periodic Income Tax Notification Letters Article 15, Article 22,
Article 23 and/or Article 26 as well as Evidence Withholding/collection
10. Regulation of the Director General of Taxes Number PER - 1/PJ/2011 concerning Procedures for Submitting
an Application for Exemption from Withholding and/or Collection of Income Tax by Other Parties
11. Regulation of the Director General of Taxes Number PER - 06/PJ/2013 concerning Amendments Second, on
the Regulation of the Director General of Taxes Number PER - 57/PJ/2010 concerning Procedures and
Procedures for Collection of Income Tax Article 22 in Relation to Payments for the Delivery of Goods and
Activities in the Import Sector or Business Activities in Other Fields
12. Regulation of the Director General of Taxes Number PER - 08/PJ/2014 Concerning Supervision of
Withholding/Collection and Payment of Taxes Carried out by the Treasurer of Expenditures of Regional Work
Units/Proxy of the Regional General Treasurer
13. Regulation of the Director General of Taxes Number PER - 21/PJ/2014 concerning Amendments to
Regulation of the Director General of Taxes Number PER - 1/PJ/2011 concerning Procedures for Submitting
Applications for Exemption from Withholding and/or Collection of Income Tax by Other Parties
14. Regulations of the Director General of Taxes Number PER - 19/PJ/2015 Concerning Procedures for
Collection of Income Tax Article 22 on the Sale of Goods Classified as Very Luxurious /PJ/2015
Concerning Procedures for Collection of Article 22 Income Tax on the Sale of Goods Classified as
Very Luxury
16. Regulation of the Director General of Taxes Number PER - 31/PJ/2015 Concerning the Third Amendment
to the Regulation of the Director General of Taxes Number PER - 57/PJ/2010 Concerning Procedures and
Procedures for Collection of Income Tax Article 22 Regarding Payment for Delivery of Goods and Activities
in the Field Import or business activities in other fields
17. Circular of the Director General of Taxes Number SE - 28/PJ.43/1998 concerning Income Tax Article 22 on Import
Goods for activities/services for which the compensation is solely subject to final income tax
OBJECT OF COLLECTION OF INCOME TAX ARTICLE 22
(Article 22 of Law Number 36 of 2008, 6/ PMK.03/2021)
1. Purchase of goods by the Government 2. Import

of goods or business activities in other fields 3. Sales of goods
classified as very luxurious.
SUBJECT TO COLLECTION OF TAX 1. Suppliers of

goods to the government 2. Importers/importers of
goods or suppliers/buyers of goods from agencies
certain body
3. Buyers of goods that are classified as very
luxurious.

Minister of Finance
Set
Treasurer, Certain
Agencies,
Taxpayer
Certain For
COLLECTING
TAX
Income
Income Tax
ARTICLE 22
COLLECTOR
Objects subject to Income Tax Article 22
Foreign exchange bank & DJBC Imported goods
Government Purchase of Goods from

treasurer
State Budget /Local
Budget
Business entities: cement, Sales of Results

paper, steel, automotive Production in
Domestic
Sales of fuel, gas,

Manufacturer/importer Lubricants
Industry/exporter:
Material Purchase from
forestry, agriculture,
gardens, Collector Traders
fish
Sale of goods
Taxpayer Certain
Entities Very Luxurious
IMPORTED GOODS
Subject to Tax Collection Article 22 Import Income
Tax rates are imposed on
Import Value, which is the
Imported goods importer
value in the
form of money which is the
basis for calculating BM,
namely CIF plus BM and
other levies imposed
Income Tax Article 22 Import based on the provisions
= 2.5% of customs laws and
No API (Number Unoccupied Items = 7.5%
Import Identifier) = 7.5% of the auction sale price
regulations in the import
sector.
CIF (Cost Insurance
Import Duty = Import Value
and Freight) +
DEBT AND PAID OUT
BM Payment PIB Doc Completion

Description Currency Mark
cost USD 500,000
Insurance USD 10,000
freight USD 40,000
Import Duty USD 110,000

(20%)
PT AJUS AJAN on August 27 2020 bought goods to the United States at a price of USD
500,000. it is known that the company has an API issued by the trade department and
at the time of purchase the KMK exchange rate was IDR 8,000 per USD.
1. Based on this information, calculate the Income Tax 22 payable 2. And on the
same day the company's partner, namely PT DON'T BE YOU, buys the same goods, but
the company does not have an API. Then how is Income Tax 22 owed?

PURCHASE OF GOVERNMENT GOODS
Directorate General of Budget,
PAYMENT Customs (import)

Government Treasurer
For Purchase of Goods
(CENTRAL/REGIONAL)
Appointed as Income Tax Collector Article 22
Income Tax Law Article 22
LEGAL BASIS - PMK 34/PMK.010/2017

- PMK 92/PMK.03/2019
RATES 1% X Purchase Price (before VAT)

2%
Income Tax If the partner does not have
TIN/NPWP, then it will be charged 100%
Nope
TIN/
NPWP
higher
Article 22
CERTAIN BUSINESS ENTITIES
SALES OF PRODUCTION PRODUCTS IN THE COUNTRY
CEMENT INDUSTRY 0.25% x tax Base VAT NOT FINAL
PAPER INDUSTRY 0.1% x tax Base VAT NOT FINAL
STEEL INDUSTRY 0.3% x tax Base VAT NOT FINAL
AUTOMOTIVE INDUSTRY 0.45% x tax Base VAT NOT FINAL
“Debt And Collected

At the Time of Sale”
SALES OF CERTAIN PRODUCTS
PERTAMINA Non PERTAMINA
0.25% x 0.3% x
fuel oil Sale Sale
0.3% x 0.3% x
fuel gas
O
S
T
OA
G
FA
N
HE
N
A
F
UD
S
E
LL
E
,
IFACTTURER
C
LBTMOUHYARBENRU
Sale Sale
0.3% x 0.3% x
LUBRICANT
Sale Sale
To dealers/ agents that are final, other than dealers/ agents that are not final
COLLECTOR TRADERS
Buying Materials For
agriculture Industrial Interests/Export From
Collector Traders
Collected
forestry owed Income Tax
Article 22
Plantation Rates
At the time
of purchase
fishery
0.25% X
Purchase

SALE OF LUXURY GOODS
PMK Number 253/ PMK.03/2008 amended PMK Number 92/ PMK.03/2019
1. private aiIDRlanes and private helicopters; 2.

yachts, yachts, and the like; 3. the house and the
land, at a selling price or price
transfer of more than IDR 30,000,000,000.00 (thirty billion rupiah) or a
building area of more than 400m2 (four hundred square meters);
4. apartments, condominiums, and the like, with a selling price or transfer of

more than IDR 30,000,000,000.00 (thirty billion rupiahs) or a building
area of more than 150m2 (one hundred and fifty square meters); 5.
four- wheeled
motorized vehicles for transporting less than 10 people in the form of sedans,
jeeps, sport utility vehicles (SUV), multi-puIDRose vehicles (MPV),
minibuses, and the like, with a selling price of more than IDR.
2,000,000,000.00 (two billion rupiah) or with a cylinder capacity of more than
3,000cc;
and/or
6. two- and three-wheeled motorized vehicles, with a higher selling price
from IDR 300,000,000.00 (three hundred million rupiah) or with a cylinder
capacity of more than 250cc. Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP
RATES
AMOUNT OF INCOME TAX IS:
1% of the selling price excluding VAT and VAT on Luxury

Goods for the goods referred to in points 3 and 4 above;
And 5% of the selling price excluding VAT and VAT on
Luxury Goods for the goods referred to in points 1, 2, 5
and 6.
SUCH INCOME TAX 22 CAN BE CALCULATED AS INCOME TAX PAYMENTS

IN THE CURRENT YEAR FOR TAXPAYERS WHO PURCHASE VERY LUXURY
GOODS.

Income
Tax 22
PT Semen handed over 100 sacks of cement @ IDR 75,000.00 to the Provincial Government of Bali for
infrastructure projects. The amount of the levy and the person who collects Income Tax Article 22 on
the transaction is
a. IDR. 75,000.00 by the Provincial Government
b. IDR. 18,750.00 by the Provincial Government
c. IDR 75,000.00 by PT Semen Gresik
d. IDR. 18,750.00 by PT Semen
Gresik Answer: Bali Provincial Government Bend = 1% x IDR.7,500,000 = IDR. 75,000, SSP an PT Semen
and can be credited in the Annual SPT

Inco
me
Tax
PT Renjo, has API, TIN/NPWP: 01.345.736.7.013.000, domiciled at Jl.
Kembangan No 13, Kebayoran Lama, South Jakarta, on February 12 2010 imported
BKP in the form of 10 computers costing IDR 100,000,000.00. The Taxable Goods
are subject to Storage Fees, BM, BMT, and VAT on Luxury Goods of 10%, 15%, 15%
and 10% of the basic price, respectively. Income Tax Article 22 collected by DGCE
is…..
a. IDR 2,500,000.00
b. IDR 3,125,000.00
c. IDR 3,250,000.00
d. IDR3,500,000.00
Answer:
Import Value = CIF+BM+BMT=100,000,000+10,000,000+15,000,000= 125,000,000
Income Tax 22 = 2.5% x 125,000,000= 3,125,000

Inco
me
Tax
PT Bank Mandiri purchased 1 Used Truck from PT PLN in May 2013 at a price
of IDR 110,000,000 per unit. The amount of the levy and the person who
collects Income Tax Article 22 on the transaction is
a. IDR 1,500,000.00 by PT Bank Mandiri
b. IDR 1,500,000.00 by PT PLN
c. IDR 1,100,000.00 by PT PLN
d. IDR. 1,100,000.00 by PT
Bank Mandiri Answer: Article 22 = 1% x

110,000,000 = 1,100,000 .. there are no
words includi

Inco
me
Tax
Rony has an TIN/NPWP, is a ATK sales entrepreneur, submits ATK to the Municipal
Government with a value of IDR 1,500,000.00 (not including VAT). How much tax must
be collected by the Government Treasurer in the amount of
a. IDR 150,000.00
b . IDR 22,500.00
c . IDR 27,000.00
d. There isn't any
Answer :
Because under IDR 2,000,000, Article 22 Income Tax is not collected

Inco
me
Tax
The treasurer of SMPN 1 INGGRIS bought general textbooks for schools in the amount of
IDR 11,000,000 (price includes VAT) to Publisher Erlangga, how much is Article 22 income
tax payable?
a. Not payable Income Tax Article 22
b. IDR. 500,000
c. IDR. 150,000
d. IDR. 110,000
Answer:
Ps 22 = 1% x 11,000,000 = 110,000 because VAT is exempt from general textbooks

Inco
me
Tax
The treasurer of the Municipal Government of Denpasar Madya City pays electricity in the amount
of IDR. 5,000,000 (not including VAT), then how much Income Tax Article
22 is payable?
a. Not payable Income Tax Article 22
b. IDR. 75,000
c. IDR 250,000
d. IDR. 0
Answer: Because electricity payments are
excluded Ps 22

Inco
me
Tax
Dino Susilo places an order by issuing a delivery order. On March 9, 2013, received
delivery/delivery of BBM on March 19, 2013 and sold BBM during March 20-30 2013.
Income tax Article 22 on the sale of BBM, gas fuel and lubricants is payable and collected
by Pertamina when….
a. Issuance of delivery orders
b. Delivery of fuel oil, gas fuel and lubricants
c. Submission of bills
d. Payment of bills
Answer: PMK 224/ PMK.11/2012 regulates the collection of

Article 22 Article 4 paragraph 5; Income Tax Article 22 on
the sale of fuel oil, CNG, Lubricants payable and collected at
the time of issuance of delivery orders

Inco
me
Tax
If the fuel procurement transaction is carried out in the amount of IDR. 500,000,000
(excluding VAT) , Article 22 Income Tax must be paid...
a. 0.25% x purchase price and is final for Dino Susilo
b. 0.30% x purchase price and is not final for Dino Susilo
c. 0.25% x purchase value and is final for PT Pertamina
d. 0.30% x purchase value and is final for PT Pertamina
Answers: -
Article 2 paragraph 1 and Article 9 paragraph 2 PMK 224/PMK.11/2012; Dino resells the fuel
he has purchased, so he is considered a dealer, so Article 22 Income Tax is 0.3% and is final.

Income Tax ARTICLE 23
LEGAL BASIS
1. Law Number 36 of 2008 concerning the Fourth Amendment to Law Number 7 of 1983 concerning Income Tax.
2. Law Number 11 of 2020 Concerning Job Creation 3.
Government Regulation Number 94 of 2010 Regarding Calculation of Taxable Income and Payment of Income Tax in the Current Year Government Regulation Number 45 of
4. 2019 concerning Amendments to Government Regulation Number 94 of 2010 concerning Calculation of Taxable Income and Payment of Income Tax in the Current
Year Minister of Finance Regulation Number 251 /PMK.03/2008 Concerning Income on
5. Financial Services Performed by Business Entities that Serve as Loans and/or Financing Agents That Do Not Withholding Income Tax Article 23 Regulation of the Minister of
Finance Number 39/PMK.011/2013 Concerning Obligations with Withholding and/or Collection of income tax owed to other parties
6. by companies bound by production sharing contracts, contracts of work, or mining concession cooperation agreements. C Number 2 Law Number 7 of 1983 Concerning
Income Tax As Amended Several Times Lastly By Law Number 36 of 2008 Regulation of the Minister of Finance Number 6/PMK.03/2021 Concerning Calculation and
. Collection of Value Added Tax and Income Tax on Delivery /Income in connection with the sale of Credit, Starter Pack, Tokens and Vouchers Decree of the Minister of
Finance Number 1169/KMK.01/1991 Concerning Leasing Activities
8.
9.
10. Regulation of the Director General of Taxes Number PER - 15/PJ/2014 Concerning the Use of a Signature Stamp on Income Tax Withholding Evidence
On Payment of Dividends to Shareholders
11. Circular Letter of the Director General of Taxes Number SE - 53/PJ/2009 Concerning the Gross Amount As Meant in Article 23 Paragraph (1) Letter C Number 2 Law Number 7 of
1983 Concerning Income Tax As Amended Several Times Last By Law Law Number 36 of 2008
12. Circular Letter of the Director General of Taxes Number SE - 58 /PJ/2009 Concerning Submission of Regulations of the Director General of Taxes Number PER - 33/PJ/2009
Concerning Income Tax Treatment of Income in the Form of Royalties From Cinematographic Works
13. Circular Letter of the Director General of Taxes Number SE - 35/PJ/2010 Concerning the Definition of Rent and Other Income in Relation to the Use of
Assets, Technical Services, Management Services, and Consulting Services As Referred to in Article 23 Paragraph (1) Letter C Law Number 36
Year 2008 concerning the Fourth Amendment to Law Number 7 of 1983 concerning Income Tax
14. Circular of the Director General of Taxes Number SE - 06/PJ/2015 Concerning Withholding and/or Collection of Income Tax on Transaction E
Commerce
15. Circular of the Director General of Taxes Number SE - 57/PJ/2015 concerning Affirmation of the Treatment of Withholding and/or Collection of Income Tax Based on Regulation
of the Minister of Finance Number 39/PMK.011/2013 Concerning Obligations of Withholding and/or Collection of Income Tax Payable to Parties Others By Companies
That Are Bound By Production Sharing Contracts, Contracts Of Work, Or Mining Operations Cooperation Agreements
16. Circular Letter of the Director General of Taxes Number SE - 70/PJ/2015 Concerning Affirmation of the Implementation of Collection of Income Tax Article 22 in Relation
With Payment for Delivery of Goods and Activities in the Import Sector or Business Activities in Other Fields

Income Tax Article 23
Government Agency.
Give Income
Domestic Tax Subject.
Activity Organizer. Paid,

By name and in provided to be
form
paid, JT
Permanent Business Entity (BUT) whatever
Payment
Representatives of Other
Overseas Companies.
CUT
Individuals as Taxpayer appointed
by the Head of KPP. TAX

CUTTING OBJECT
Income Tax Article 23
Rent And Other Income In Connection

With the Use of Property
On
Benefits in Relation to:
• Engineering Services;
• Management Services;
• Legal Consulting Services,
• Tax Consulting Services,
• OTHERSERVICES BESIDES THE
SERVICES THAT HAVE BEEN
Payment CUT Income Tax PSL 21

In the form of Derived From Capital:
Dividends
Interest
Royalties

PROVISION
Provision Cutter The Cut object Characteristic
Income Tax Law Domestic OP : Passive income Not Finals

Royalty Dividend Interest
Agency
UU KUP Appointed OP Body : Active + Passive Rent, Services
PMC 244 Bookkeeping OPs
Appointed Op
Experts who do Free Work
Op Bookkeeping Business
Withholding Income Tax Article 23, above
Payment in connection with Rent

When Payable Income Tax Article 23
When paid
Provided paid
Fall Available Contract

Tempo to pay Agreement
Payment due Dividend / Invoice
End of month payment /
payable income /
Which comes first

Rent property Rates
Engineering Services
Cutting
2%
Service Income Tax Article 23
Management
Consulting Services
Other Services
RATES
Flower
Dividend
15%
Royalties Prizes have been changed

in PER -11/PJ/2015
Present

PT PRAMANA (first party) entered into a contract with PT EMIR an advertising
agency company (Second Party) to make advertisements as well as placing
advertisements at PT AGUNG (Third Party). The agreed contract value is IDR
103,000,000. in the billing note is specified as follows;
1. Purchase of advertising materials of IDR. 5,000,000
2. Consulting services of IDR. 5,000,000
3. Agent management fee of IDR. 3,000,000
4. Cost of advertising to media companies IDR. 90,000,000
Calculate
1. Withholding Income Tax 23 made by PT EMIR for the cost of advertising to
PT AGUNG
2. Withholding Income Tax 23 made by PT PRAMANA for payment of
consulting services and agency services to PT EMIR
3. How is Income Tax 23 deducted if PT EMIR has no supporting evidence for
the details of the bill?

Interest
Interest
FLOWER
Paid Paid
company
Bank including
cut
Final Income Banks Individuals Corporates
Tax Premiums, discounts,
debt
repayment guarantees
Deduction of Deduction of
Uncut Income Tax 23 Income Tax 23
Tax

DIVIDEND
Some Understanding Regarding dividends
Share of Earned Profit:
1. Repayment due to liquidation that exceeds the amount

of paid-up capital.
2. Provision of bonus shares without deposit. Including bonus
shares from premium capitalization.
3. Repayment of paid-in capital, if profits were obtained in
past years, except as a result of legally reducing
authorized capital.
4. Company expenses for the personal needs of What about

shareholders which are charged as company costs SHOUTH DIVIDEND?

DIVIDEND
Accepted Accepted Accepted Accepted
•limited liability company • limited liability company

• CV •Cooperative •Member
•State-Owned Cooperative
Enterprise (SHU)
•Local-Owned
Enterprise
Minimum 25% share
Origin of reserves of retained earnings Cuting Final

NOT CUT
Income Tax 23 Income Tax
Non-taxable income
RENT
The
agreement gives
the right to use the
property for a certain
period of
time, whether
written agreement
or not, the
property can
only be
used by the
recipient of
the right
for the Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP
TYPE OF SERVICE
Provision of services in the form of
providing information relating to industrial,
trade and scientific experience
Provision of services by participating directly
and responsibly in carrying out
management
Provision of professional advice in a field
of business or work carried out by
expert associations
Copyright use, use film, copyright

release
Royalties Engineering Services Management Consulting Services

Base Character Deposit Reporting
Rates
No object Counting istic deadline
deadline
2% Gross Next Next
technical services, management services, services Amount*
Construction, consulting services 10 months 20 months
15% Gross Amount* Next Next

Dividends, Interest, Royalties, Prizes
10 months 20 months
Rent and other income in connection 2% Gross Amount* Next Next

with the use of assets except Land and/ or 10 months 20 months
Rent
Building
Other Service Fees
Appraisal Services 2% Gross Amount* Next Next

10 months 20 months
Actuary Services 2% Gross Amount* Next Next
10 months 20 months
Accounting services, bookkeeping and 2% Gross Amount* Next Next

attestation of financial reports 10 months 20 months
Design Services 2% Gross Amount* Next Next

10 months 20 months
Drilling services in the field of oil and 2% Gross Amount* Next Next
gas mining, except for those 10 months 20 months
carried out by PE
Supporting services in the field 2% Gross Amount* Next Next

of oil and gas mining 10 months 20 months
No Object Rates istic
Counting deadline deadline
Mining services and services 2% Gross Amount* Next Next
support in the mining sector other than oil 10 months 20 months
and gas
Supporting services in the field 2% Gross Amount* Next Next
of aviation and airports 10 months 20 months
Forest logging services 2% Gross Amount* Next Next

10 months 20 months
Waste management services 2% Gross Amount* Next Next

10 months 20 months
Labor supply services (outsourcing 2% Gross Amount* Next Next

service) 10 months 20 months

Intermediary or agency services
10 months 20 months
Services in the field of securities trading,
except those carried out by the 10 months 20 months
Stock Exchange, KSEI and KPEI
Custodian/safekeeping/safekeeping
services, except those performed by KSEI 10 months 20 months
Voice filling services (dubbing and/ or
dubbing). 10 months 20 months
Mining services and supporting
services in the mining sector other than oil 10 months 20 months
and gas

Rates
No Object
istic deadline deadline
Counting
16. Film mixing services 2% Gross Next Next
Amount* 10 months 20
months
17. Services related to computer software, 2% Gross Amount* Next
including care, maintenance and repair 10 months Next
20
months
18. Installation/installation of machinery, 2% Gross Amount* Next Next
equipment, electricity, telephone, water, 10 months 20
gas, air conditioning, and/or Cable TV, months
other than those performed by
taxpayers whose scope is in the
construction sector and have permits
and/or certificates as construction
entrepreneurs
19. Maintenance/repair services 2% Gross Amount* Next Next

/maintenance of machines, equipment, 10 months 20
telephone electricity, water, months
gas, air conditioning, and/or
Cable TV, transportation
equipment/vehicles and/or buildings,
other than those carried out by
taxpayers whose scope is in the
construction sector and have a
certificate as a construction entrepreneur
20. Toll service 2% Gross Amount* Next Next
10 months 20 months

Rates
Base Characteri Deposit Reporting
No Object
Counting stic deadline deadline
21. Investigation and security services 2% Gross Amount* Next Next
10 months 20 months
22. Services for organizing activities or event 2% Gross Amount* Next Next
organizers 10 months 20 months
23. Packing services 2% Gross Amount* Next Next

10 months 20 months
24. Services for providing a place and/or time 2% Gross Amount* Next Next
in mass media, outdoor media or other 10 months 20 months
media for conveying information
25. Pest extermination services 2% Gross Amount* Next Next

10 months 20 months
26. Cleaning services or cleaning service 2% Gross Amount* Next Next
10 months 20 months
27. Catering/catering services 2% Gross Amount* Next Next
10 months 20 months

MACLOON SERVICES
PROVIDED
•Settlement SERVICE USER
Service Users
Goods
Performed by •Specifications, raw
materials, semi-
service
finished, auxiliary
providers
•Partial/whole
OWNERSHIP
PROVISION OF SERVICES
GOODS

PT I LOVE YOU is a company engaged in the security services business.
On May 18, 2022 the company received payment for security services provided to
PT PEMELOLA BUILDING. The Billing Department bills with detailed data as
follows: security services IDR 8,000,000, wages for security personnel IDR
20,000,000, administrative fee allocation IDR 2,000,000 so that the total invoice is
IDR 30,000,000.
The amount of Income Tax Article 23 that is
deducted is
a. IDR 160,000
b . IDR 200,000
c. IDR 600,000
d. There is no correct answer
Answer: Labor services are broken down so that
labor wages do not count (2%x (8 milli
2 million))

Income
Tax (3)
Mrs. SUKMA has an TIN/NPWP and is a catering entrepreneur who received an order
from the Municipal Government for the celebration of the 65th Indonesian Independence Day
with an order value of IDR 10,000,000.00 (not including 10% local tax). Income Tax Article
23 that must be deducted by the Government Treasurer is:
a. IDR 150,000.00
b. IDR 180,000.00
c. IDR 200,000.00
d. IDR 240,000.00
Answer:
No answer, Article
21 Income Tax
should be deducted
because the
Taxpayer OP

Income
Tax (4)
Pak To invests his money in PT Parti and receives dividends in the same amount from year to year since
2011, namely IDR 10,000,000.00 per year. How much tax and what type of tax is deducted this year is
a. IDR. 0.00 and Income Tax 23
b. IDR. 1,000,000.00 and Final Income Tax
c. IDR. 1,000,000.00 and Income Tax 23
d. IDR. 1,500,000.00 and Income Tax 23
Answer :
Article 17 (2c) dividend Taxpayer OP 10% x 10 million = 1

million

Income
Tax 23 (6)
PT Inti Bumi made a transaction with CV Surya Catering to provide lunch at the Office
Anniversary event for 50 people in the amount of IDR 1,000,000, however Cv
Surya catering provided its own materials of IDR 250,000, and hired security
personnel from PT Aman Jaya with the total cost consisting from a service fee of 500
thousand and a security guard wage of IDR. 500 thousand but not detailed in the
invoice.
How big is the object of withholding Income Tax Article 23
…..
a. IDR. 1,500,000
b. IDR. 1,750,000
c. IDR. 2,000,000
d. IDR. 2,250,000
Answer:
It's in PMK 244 2008;
1 million catering + unspecified security costs 1 million = 2
million
LEGAL BASIS
1. Law Number 11 of 2020 concerning Job Creation 2. Minister of Finance
Regulation Number 258/PMK.03/2008 concerning Withholding Income Tax Article 26 on Income from the Sale or Transfer of Shares as Meant in Article 18 Paragraph (3c) of the
Tax Law Income Received or Earned by Foreign Taxpayers 3. Regulation of the Minister of Finance Number 82/PMK.03/2009 concerning Regulation of the Minister of Finance
concerning Withholding Tax Article 26 on
Income from the sale or transfer of assets in Indonesia, except for what is regulated in Article 4 paragraph (2) of the income tax law, which is received
Or obtained by foreign taxpayers other than permanent establishments in Indonesia
4. Regulation of the Minister of Finance Number 14/PMK.03/2011 concerning Tax Treatment of Taxable Income After Tax is Deducted from an
Permanent Establishment.
5. Regulation of the Minister of Finance Number 39/PMK.011/2013 concerning Obligations with Withholding and/or Collection of Income Tax Payable to
Other Parties by Companies
that are Bound by Production Sharing Contracts, Contracts of Work, or Cooperation Agreements on Mining Operations 6. Regulation of the Minister of Finance
Number 202/PMK.010/2017 Concerning the Implementation of Income Tax Treatment Based on the Provisions in
International Agreement
7. Regulation of the Minister of Finance Number 236/PMK.010/2020 concerning Amendments to Regulation of the Minister of Finance Number 202/PMK.010/2017
concerning Implementation of Income Tax Treatment Based on Provisions in International Agreements
8. Decree of the Minister of Finance Number 624/KMK.04/1994 concerning Withholding Income Tax Article 26 on Income in the Form of Insurance Premiums
and Reinsurance Premiums Paid to Insurance Companies Overseas 9. Decree of the
Minister of Finance Number 434/KMK.04/1999 concerning Withholding Income Tax Article 26 on Income Received or Earned
Foreign Taxpayers Other than Permanent Establishments on Income in the Form of Profits from the Sale of Shares
10. Regulation of the Director General of Taxes Number PER - 16/PJ/2011 concerning Procedures for Notifying Taxpayers of Permanent Establishment of
Reinvestment
Taxable Income After Deducting Tax
11. Regulation of the Director General of Taxes Number PER - 25/PJ/2018 concerning Procedures for Applying Double Taxation Avoidance Agreements 12.
Circular Letter of the Director General of Taxes Number SE - 22/PJ.22/1988 Concerning Income Tax Article 26 on Foreign Credit Interest
13. Circular Letter of the Director General of Taxes Number SE - 23/PJ.43/1995 Regarding Explanation of Instructions for Withholding Income Tax Article 21 and Article 26 (Income Tax
Article 21 Series) Number 4)
14. Circular Letter of the Director General of Taxes Number SE - 25/PJ.4/1995 Concerning Withholding Income Tax Article 26 For Payment of Insurance Premiums Overseas (Income Tax
Series Article 23/26 Number 5)
15. Circular Letter of the Director General of Taxes Number SE - 04/PJ.34/2005 Concerning Guidelines for Determining "Beneficial Owner" Criteria as Set Out in
Agreement on the Avoidance of Double Taxation Between Indonesia and Other Countries
16. Circular Letter of the Director General of Taxes Number SE - 57/PJ/2015 Concerning Affirmation of Income Tax Withholding and/or Collection Treatment
Based on the Regulation of the Minister of Finance Number 39/PMK.011/2013 concerning Obligations of Withholding and/or Collection of Income Tax Payable to Other
Parties by Companies Bound by Production Sharing Contracts, Contracts of Work, or Cooperation Agreements on Mining Operations
17. Circular Letter of the Director General of Taxes Number SE - 19/PJ/2016 Concerning Procedures for Implementing International Tax Activities 18.
Circular Letter of the Director General of Taxes Number SE - 04/PJ/2017 Concerning Determination of Permanent Establishment for Foreign Tax Subjects Providing
Application Services and/or Content Services Via the Internet

SUBJECT & OBJECT Income Tax
Article 26
subject OBJECT
Gifts, pensions,
Representative Dividends, interest,
premise swaps,
Government royalties,
Outside gains on debt relief
Agency, compensation for
Company
SPDomestic, EO, services, jobs, acti
BUT, Other Country;

RATES & OBJECT
WHEN WERE OBTAINED

Interest, dividends,
26 (1)
royalties, rent, General:
20% X Gross Amount • End of month
Rewards, gifts,
payment or outstanding
premiums, debt relief
income, whichever
comes first.
Transfer of property in Special:
26(2), 26(2a) Indo, transfer of
• When due interest
Rates
shares in Indo
20% X Net Amount and rent
Payment of insurance • When available for paid
premiums, transfer of
shares dividends
26 (4) • When specified in the
contract agreements, or
20% X (PKP – Tax) Branch Profit Tax
• Invoices royalties,
services

Article 26 (2)
Income from the sale or transfer of assets in Indonesia, except for those stipulated in Article 4
paragraph (2) of the Income Tax Law, consists of:
- Luxury jewelery - Gold - Diamonds – Luxury - Diamond
watches - Antiques - Paintings - Cars - Cruise ships, and/or - Light aircraft Except for those
received/acquired by Overseas Individual Taxpayer
whose value does not exceed IDR 10,000,000 (Ten million rupiah) for
each transaction
Tariff = 20% of estimated net income

Estimated net income = 25% x selling price
Effective rate = 5% x selling price
Cut by Buyer (appointed)
20% X Estimated Ph. Net ; •

Insurance premiums paid to overseas
Payer / Deductor -> Insured : 20% x 50% = 10 % Effective rate •
insurance companies (either directly or
Payer / Deductor -> Company.Insurance : 20% x 10% = 2 % Effective
through brokers)
rate • Payer / Deductor -> Perush.Reinsurance : 20% x 5% = 1 % Effective ra

Article 26 (2a)
Income from the sale or transfer of

shares as referred to in Article 18
paragraph (3c)
Income Tax Law
Tariff = 20% of estimated net income

Estimated net income = 25% x selling
price
Effective rate = 5% x selling price

ILLUSTRATION
(1) X Co. owns 50% of X Co.

BVI Ltd. Formal Transactions
BVI Ltd X Co. &Y Co.

Domestic
selling BVI Ltd
(2)Y Co. Y Co. shares.
owns 50% of owned by
BVI Ltd. PT Z
(3) BVI Ltd. owns
100% of PT/BUT BVI
Abroad PT BVI PT Z
(Tax Treatment= Article 26 paragraph 2a)

PT Z is required to collect Income Tax
Article 26 (2a) of 20% of the estimated
net income at the time of purchasing BVI
Ltd shares.
CUTTING
No Tax Treaties, There is a Tax Treaty :
• subject to Income Tax • Payment of capital income,

Article 26 of 20% according to tax treaty rates,
on payment of capital unless you have BUT
income and deducted with Article 23
business income (if it has Income Tax.
not passed the time test) • Payment for free work, free of
Article 26 Income Tax as long
as you don't have BUT in
Indonesia or do not exceed
the time test

OPERATING PROFIT
Operating profit received by a company domiciled or established outside

Indonesia
•ONLY CHARGED IN INDONESIA IF THERE IS A BUT

•EXCEPT WITH COUNTRIES: GERMANY, LUXEMBOURGE,
SWITZERLAND, AND PAKISTAN FOR TECHNICAL, MANAGEMENT
AND SERVICES CONSULTANT
DETERMINING THE TIME TEST BUT FOR VARYING SERVICES

• Treaty: an international agreement that has been
concluded between countries and made in accordance
with international law.
• Tax treaty: an agreement between two or
more countries by dividing the right to tax an
income originating from a country that is obtained by
residents of other countries.
P3B: Double Taxation Avoidance Agreement

Other terms: tax treaty, double taxation agreement,
double taxation convention, double taxation treaty,
or tax conventions
Re invest Fully Embedded
Net Profit After permanent
business entity tax Equity Participation in
New Company In
Taxable 20% X Indonesia
The New Company Must
(Taxable Income – Income Tax Payable) Active Longest 1 Year
Since Founded
FINAL PROPERTIES
Latest Tax Year
Next Since Received
Income
unless implanted back in Indonesia
Not Transferred Until
(re- invest) 2 Years
After Commercial
Production

26
On May 18, 2011 PT PENGGUNA JASA paid the LAOS film patent rights to LAO
LAO. Ltd (a company in Laos) in the amount of IDR. 100,000,000.-. How much
Income Tax is deducted by PT. SERVICE USER where there is no double tax
avoidance agreement Indonesia --Laos (P3B) ....
a. The Income Tax Law with Income Tax Article 26 of IDR 20,000,000 applies
b. The Income Tax Law with Income Tax Article 23 of IDR 15,000,000 applies
c. The right to collect is in the country of LAOS
d. Tax is not deducted in Indonesia as long as you can show a Statement of
Domicile from the Country of Laos

26
Ps 2 (5) letter m Law 36/2008

Chaya-Chaya CoIDR is a foreign tax subject where the country does not have a tax treaty
with Indonesia. Chaya-Chaya provides IT consulting services to PT Emoh Loss by sending
his employee Mr. Chuck Morrack for 70 days to Indonesia with a contract value of IDR
100,000,000. What is the status of Chaya-Chaya CoIDR for providing these services and
how much tax is payable:
a. SPAbroad and Article 26 Income Tax of IDR. 20,000,000
b. Foreign tax subject and Income Tax Article 26 nil
c. Permanent business entity and Income Tax Article 23 of
IDR. 2,000,000
d. Independent Agent Income Tax is not deducted
Answer:
Article 2 paragraph 5 of the Income Tax Law regarding
BUT letter m. Provision of Services in any form by
employees or other people as long as it is carried out for
more than 60 days within a 12 month period

Oman, BKP (06.555.888.9-xxx.000) has cash of IDR 10,000,000,000.
You are asked to analyze how much investment Oman BKP (net tax) will receive
at the end of 2012. The investment data that has been made during 2012 is:
a) Purchased a luxury sedan vehicle or IDR 1,000,000,000 and

leased to PT HHH and receive rental payments of IDR 100,000,000 per year (not
including tax). Payment received on January 17, 2012
b) Purchased shares in a public company for IDR 2,000,000,000 on January 4, 2012.

Shares were sold on December 19, 2012 for IDR 2,200,000,000
c) Purchased PT DDD (a non listed trading company) for IDR
5,000,000,000 on 18 February 2012. PT DDD distributed dividends worth IDR
90,000,000 on 09 October 2012
d) Bought an apartment for IDR 1,500,000,000 on November 7, 2012 and leased it
to PT HHH for IDR 150,000,000 (excluding tax). Payment received
December 18, 2012.
Calculate the Income Tax payable for the transaction mentioned above?

ANSWER PROVISIONS
TASK
•Legal basis for answers must be included
• Questions and answers are shared on the
story ig tag @aqilamirasanty
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prizes

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COLLECTION WITHHOLDING

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

(Article 22 of Law Number 36 of 2008, 6/ PMK.03/2021)

1. Purchase of goods by the Government 2. Import

SUBJECT TO COLLECTION OF TAX 1. Suppliers of

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Foreign exchange bank & DJBC Imported goods

Government Purchase of Goods from

Business entities: cement, Sales of Results

Sales of fuel, gas,

DEBT AND PAID OUT

BM Payment PIB Doc Completion

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

cost USD 500,000

Insurance USD 10,000

freight USD 40,000

Import Duty USD 110,000

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

PAYMENT Customs (import)

Appointed as Income Tax Collector Article 22

Income Tax Law Article 22

LEGAL BASIS - PMK 34/PMK.010/2017

RATES 1% X Purchase Price (before VAT)

SALES OF PRODUCTION PRODUCTS IN THE COUNTRY

CEMENT INDUSTRY 0.25% x tax Base VAT NOT FINAL

PAPER INDUSTRY 0.1% x tax Base VAT NOT FINAL

STEEL INDUSTRY 0.3% x tax Base VAT NOT FINAL

AUTOMOTIVE INDUSTRY 0.45% x tax Base VAT NOT FINAL

“Debt And Collected

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

1. private aiIDRlanes and private helicopters; 2.

4. apartments, condominiums, and the like, with a selling price or transfer of

1% of the selling price excluding VAT and VAT on Luxury

SUCH INCOME TAX 22 CAN BE CALCULATED AS INCOME TAX PAYMENTS

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Bank Mandiri Answer: Article 22 = 1% x

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Answer: PMK 224/ PMK.11/2012 regulates the collection of

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Activity Organizer. Paid,

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Rent And Other Income In Connection

Payment CUT Income Tax PSL 21

Endah Mirasanty SH, SE., Ak., M. Ak., CA, BKP

Provision Cutter The Cut object Characteristic

Income Tax Law Domestic OP : Passive income Not Finals

UU KUP Appointed OP Body : Active + Passive Rent, Services

PMC 244 Bookkeeping OPs

Withholding Income Tax Article 23, above

Payment in connection with Rent