Revised Tax Treatments for Book Value Utilization During BUMN Restructuring: Mandatory Four-Year Business Continuity Now Required Post-Transaction

In 2024, the Minister of Finance (“Minister”) established Regulation No. 81 of 2024 on Tax Provisions for the Implementation of the Core Tax Administration System, which was subsequently amended several times, most recently by Regulation of the Minister No. 54 of 2025 (collectively referred to as “Regulation 81/2024”). This omnibus framework consolidates various tax-compliance-related Regulations. In order to support the ongoing transformation of State-Owned Enterprises (Badan Usaha Milik Negara – “BUMN”), the Minister has now introduced a further amendment to Regulation 81/2024 through the issuance of Regulation No. 1 of 2026 (“Fourth Amendment”), which has been in force since 22 January 2026.[1]