What’s New
Indonesia’s Directorate General of Taxes (DJP) laid out three key facilities in a public statement on August 19, 2026 to support tax-neutral restructuring of State-Owned Enterprises (BUMNs):
- Fasilitas Nilai Buku (non-recognition / deferred taxation on asset transfers within group),
- Implementation of PMK 1/2026 and PMK 44/2026, and
- Emphasis on Tax Control Framework (TCF) and stricter requirements for taxpayer representatives. (pajak.go.id)
These changes are aimed at supporting corporate streamlining by offering certainty and transparency. The non-recognition rule defers tax until the asset is sold outside the group; the taxpayer representative rules now require technical competency or proper registration. (pajak.go.id)
Preconditions & Requirements
To qualify for the Nilai Buku facility, BUMNs must satisfy:
- A valid Business Purpose Test (BPT), and
- Assets cannot be transferred outside the group within two years after restructuring.
For appointing a Kuasa Wajib Pajak (tax representative):
- Must be either a licensed tax consultant, or another individual satisfying technical competence (with registration as SKT), or family up to second degree.
- When appointing via power of attorney—can be electronic or physical.
- Registration in DJP’s system required. (pajak.go.id)
What is TCF?
The Tax Control Framework is DJP’s tool for cooperative compliance:
- Aligns companies’ financial accounting (General Ledger) with tax return submissions to avoid disputes.
- Requires strong internal controls, risk assessments, and making consistent tax governance part of corporate operations.
Actionable Advice
- Before restructuring, document and justify all entity changes with BPT evidence. Include financial projections and group structure roadmaps.
- Map all inter-company asset transfers and ensure no “leakage” outside group during two-year threshold.
- Evaluate whether your current tax representatives meet the technical/registration-based requirements; update agreements as needed.
- Implement or enhance tax governance and internal audit functions to prepare for compliance under TCF.
Example
Wanted to consolidate manufacturing units under one holding company: the entity transfers machines and land to the holding company within the group. Under Nilai Buku, tax on those assets is deferred until sold externally. They appoint a family member as representative, but that person needs SKT registration and competency certification due to PMK 44/2026. They also upgrade their accounting and tax reporting system so their GL is ready to match submissions under TCF.
Considerations & Risks
- Losing eligibility if transfer is outside group within two years.
- High compliance and documentation burden—business purpose, internal controls, audit trails must be strong.
- Representational mistakes: improper appointment or unqualified representative can nullify benefits or invite penalties.