1. Who this guide is for
This guide is for groups whose ultimate parent is located in Indonesia and their advisors. Indonesian entities in groups with an overseas ultimate parent can also have domestic top-up tax and reporting obligations.
Pillar Two generally covers multinational groups with consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years, subject to special rules. Confirm the ultimate parent, consolidation perimeter and entity classifications before assessing exposure. The 15% minimum rate is tested using the applicable GloBE calculations, rather than the statutory corporate income tax rate alone.
2. Why parent location matters
PMK 136/2024 introduces DMTT and IIR from 1 January 2025, with UTPR from 1 January 2026. Indonesian parents may face IIR on relevant overseas profits, while Indonesian entities must assess domestic DMTT and any allocated UTPR.
Domestic top-up taxes generally take priority, followed by IIR and residual UTPR, subject to the applicable coordination rules. Domestic enactment, OECD qualification and safe-harbour eligibility are separate questions.
3. Questions about overseas operations
- Which overseas domestic top-up taxes affect the Indonesian IIR calculation?
- How do Indonesian tax holidays, incentives and deferred taxes affect GloBE ETR?
- Do investment entities, joint ventures or partly owned parents require separate calculations?
4. Local implementation information by rule and financial period
| Rule | Status | Applicable period | Source |
|---|---|---|---|
| DMTTDomestic Minimum Top-up Tax (DMTT) | Enacted and operative | From 1 January 2025 | PMK 136/2024 — Global Minimum Tax |
| IIRIncome Inclusion Rule (IIR) | Enacted and operative | From 1 January 2025 | PMK 136/2024 — Global Minimum Tax |
| UTPRUndertaxed Profits Rule (UTPR) | Enacted and operative | From 1 January 2026 | PMK 136/2024 — Global Minimum Tax |
The table distinguishes domestic implementation from OECD qualification. Qualification and safe-harbour eligibility must be checked for the relevant rule and period. Absence from the OECD Central Record does not establish non-enactment or non-qualification. Where implementation is described as not established, this identifies a limitation of the sources reviewed.
5. Potential reliefs requiring assessment
- Test domestic safe-harbour requirements under the Indonesian rules. Do not treat an OECD publication alone as proof that a later simplification applies domestically.
- Assess the transitional CbCR safe harbour using qualifying reports and financial data. The OECD extension covers fiscal years beginning on or before 31 December 2027 and ending no later than 30 June 2029. The simplified ETR threshold is 16% for years beginning in 2025 and 17% for years beginning in 2026 or 2027. Confirm domestic application in the jurisdiction applying the rule.
- Subject to eligibility conditions, a jurisdiction can qualify by meeting any one of three transitional CbCR tests: revenue below EUR 10 million and profit before income tax below EUR 1 million; the applicable simplified ETR threshold; or profit before income tax no greater than the substance-based income exclusion. Use the prescribed qualifying data and check the “once out, always out” restriction and its exceptions. These tests differ from the permanent GloBE de minimis exclusion, which generally uses three-year averages.
- Assess the QDMTT Safe Harbour, the Simplified ETR Safe Harbour, the Substance-based Tax Incentive Safe Harbour and relevant entity exclusions separately. Their conditions, elections and effective periods differ. An OECD agreement alone does not establish domestic implementation. Do not assume that Side-by-Side relief applies merely because the group has operations in the United States.
- Relief from top-up tax does not automatically remove registration, notification, return or record-keeping obligations. Retain evidence supporting every relief claimed.
6. Reporting considerations
DJP guidance requires an application for GloBE taxpayer status generally within nine months after the first GloBE year ends.
Distinguish the annual GloBE income tax return from GIR and notification obligations. The annual return is generally due within four months after year end; the first-year deadline may be extended by up to two months through notification. GIR and notification are generally due within 15 months, or 18 months for the first GloBE year. Foreign GIR filing relief depends on the applicable conditions and exchange arrangements.
7. Information to prepare
- Ownership chart identifying the ultimate parent, intermediate parents, permanent establishments and ownership percentages.
- Consolidated financial statements and revenue for the four preceding fiscal years.
- Country-by-country reports and the financial records supporting them.
- Jurisdictional accounts, current and deferred taxes, tax incentives, credits and losses.
- Eligible payroll costs and tangible asset carrying values by jurisdiction.
- A compliance register showing responsible entities, elections, registrations and filing deadlines.
- GloBE taxpayer status applications and identification of each responsible Indonesian taxpayer.
- Separate calendars for annual returns, GIR, notifications and payments.
8. Official sources
- GloBE Model Rules — December 2021OECD
- Consolidated Commentary to the GloBE Model Rules — 2026OECD
- Side-by-Side Package — January 2026OECD
- Central Record for the Global Minimum TaxOECD
- PMK 136/2024 — Global Minimum TaxIndonesian Directorate General of Taxes
- GloBE Top-up Tax MechanismsIndonesian Directorate General of Taxes
- GloBE Compliance ObligationsIndonesian Directorate General of Taxes
These links lead to official legislation, guidance or subject-specific resources. The official texts govern.
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