Indonesia Issues Implementing Regulations for Pillar 2 Global Minimum Tax

On 31 December 2024, Indonesia's Ministry of Finance issued Regulation No. 136 of 2024, which is about implementing the Pillar 2 global minimum tax rules in Indonesia. The rules include the income inclusion rule (IIR) and the Qualified Domestic Minimum Top-up Tax (QDMTT) effective from 1 January 2025, and the undertaxed payment/profit rule (UTPR) from 1 January 2026. These apply to MNE groups with at least EUR 750 million in annual consolidated revenue in at least two of the past four years.

The regulation also defines key terms, clarifies entity scope, outlines tax calculations, and sets return and payment requirements. For example, GloBE Information Return (GIR) should be filed within 15 months after year-end (18 months for the first year), and top-up tax for a year is due by the end of the following year.

By IKPI Secretariat