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Taxpayers Meeting Certain Criteria Can Submit a Preliminary Tax Refund Application. What Are the Requirements?

JAKARTA, DMTAX – If the Annual Tax Return and/or Periodic Tax Return shows an overpayment of tax, the Taxpayer is given the right to submit a request for an advance refund of the excess tax.

Article 17C paragraph (2) of the KUP Law mandates that the DGT can issue a Preliminary Tax Excess Refund Decision Letter (SKPPKP) upon a request for a refund of excess tax payments from Taxpayers with certain criteria.

"After conducting research on the application for the refund of excess tax payments from Taxpayers with certain criteria, the Directorate General of Taxes issues a Preliminary Tax Refund Decision Letter," reads an excerpt from Article 17C paragraph (1) of the KUP Law, quoted Tuesday (30/09/2025).

Taxpayers meeting certain criteria as referred to in the legal paragraph are determined based on a Directorate General of Taxes (DGT) Decree. The DGT's primary consideration in making this decision is whether the taxpayer submits their SPT on time.

In addition, Taxpayers also do not have any tax arrears for all types of taxes, except those who have obtained permission to pay in installments or postpone tax payments.

Another criterion is that the Taxpayer's financial report is audited by a Public Accountant or government financial oversight agency with an unqualified opinion for 3 (three) consecutive years.

The final criterion that must be met is that the Taxpayer has never been convicted in the tax sector based on a court decision that has had legal force within a period of 5 (five) years.

If the Taxpayer meets the criteria referred to, the DGT can issue a SKPPKP based on the application no later than 3 (three) months from when the application is received in full for PPh, or 1 (one) month for VAT.

However, after making a preliminary refund of excess tax, the DGT can still conduct an audit of the Taxpayer.

If a tax shortfall is found, the DGT will issue an SKPKB for the amount of the tax shortfall plus an administrative sanction in the form of an increase of 100% of the amount of tax underpayment.

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