Under this newly updated framework, the qualifying criteria that must be met by taxable entrepreneurs (Pengusaha Kena Pajak "PKP") in order for them to be classified as low-risk have been expanded from eight to nine. The new addition in this regard comprises PKP who file value-added tax (Pajak Pertambahan Nilai/PPN) periodic tax returns (Surat Pemberitahuan "SPT") for overpayment restitution of up to Rp. 5 billion. Furthermore, the new framework has now revised the applicable procedures for preliminary tax overpayment refunds by extending the resubmission period for previously unaccounted tax credits to up to three years, and by requiring that decisions on corrected SPT be issued within one month of any complete correction application being received.

The Amendment has now broadened the scope of the consigned goods (Goods) that are permitted to be imported or released through free-trade zones and free ports (collectively referred to as Free Areas). Explicitly, certain criteria specific to relevant trade Goods (e.g. Goods that are derived from trading activities via electronic systems [Perdagangan Melalui Sistem Elektronik PMSE] and/or the availability of invoices as proof of transaction) no longer feature under the Amendment. Moreover, the Amendment now allows other parties (e.g. individuals or legal/non-legal business entities) to import or release Goods to and from Free Areas on behalf of foreign organizers of PMSE that have yet to appoint domestic business entities located in Indonesia to act as their representatives in relation to imports or releases of Goods.

The Indonesian Government has decided to revise the various Non-Tax State Revenue (Penerimaan Negara Bukan Pajak - "PNBP") types and tariffs that are applicable at the Ministry of Energy and Mineral Resources, allowing for more flexible tariff settings, including the possibility of tariffs being set as low as Rp. 0.00. The latest framework has also expanded the scope of PNBP sources, adding various new categories such as exploration commitments from geothermal license holders, royalties from carbon storage operations, compensation for certain activities and financial obligations. Additionally, the new framework has adjusted the applicable PNBP tariffs for various commodities, including coal, nickel, copper, gold, silver, metal, lead and zinc in an effort to streamline revenue generation within the energy and minerals sectors.

Regulation of the Director-General of Customs and Excise No. PER-3/BC/2025 on Customs Audit Standards and Excise Audits (Regulation 3/2025) introduces an updated approach to customs-and-excise audits. While auditor qualifications remain unchanged, this new Regulation removes explicit independence requirements and tightens procedures through mandatory electronic documentation and supervision, as undertaken by an Audit Quality Supervisor (Pengawas Mutu Audit PMA). Audit reporting now comprises two types: Audit Reports (Laporan Hasil Audit LHA) and Audit Termination Reports (Laporan Penghentian Audit LPA), with the latter hopefully ensuring transparency through the detailing of termination reasons, recommendations and relevant findings. This ultimately represents a step forward in terms of strengthening accountability during the auditing process.

The general audit duration has now been reduced to 21 months, replacing the previous two-year period, while investigative audits can now be conducted as required based on the scope of given assignments and object analyses. Furthermore, extension periods of up to 10 years may now be granted under certain specific circumstances, including in response to discoveries of violations during or outside an audit period, information from external parties and considerations from the audit team. An extension will apply either partially or to an entire audited object, subject to approval being granted by an authorized official.

In addition to unifying the existing frameworks for tax examinations ("Examinations"), this new Regulation has now redefined the classifications of said Examinations, which now include: 1) Thorough Examination: which covers all aspects of a tax return and/or Tax Object Notification Letter (Surat Pemberitahuan Objek Pajak SPOP); 2) Focused Examination: which focuses on one or more aspects of a tax return and/or SPOP; and 3) Specific Examination: which is specifically conducted in a simplified manner in relation to one or more items in a tax return and/or SPOP, related data or certain tax obligations.

From 1 March 2025, Regulation of the Minister of Finance ("Minister") No. 114 of 2024 on Customs Audits and Excise Audits ("Regulation 114/2024") will replace Regulation of the Minister No. 200/PMK.04/2011, as amended by Regulation of the Minister No. 200/PMK.04/2011 (collectively referred to as "Regulation 200/2011"). While maintaining the classification of audits into General, Special and Investigative categories, the new framework has now revised the General Audit period to a length of 21 months prior to the issuance of a task letter, with extensions of up to 10 years possible.

Refund applications that are submitted by individual taxpayers and that address overpayments amounting to a maximum of Rp. 100 million will be handled in line with specific special provisions. These provisions state that the refund process will be conducted based on criteria that are established for certain types of taxpayers. Furthermore, in cases where tax underpayment assessments result from refund reviews, then relevant taxpayers will be granted a reduction in their administrative sanctions, specifically a reduction in interest penalties, in accordance with the applicable Laws.

When requested by taxpayers for the purpose of filing objections or appeals, the Director-General is now required to issue certificates that detail the basis for the imposition of tax, loss calculations or tax withholding/collection. Said certificates must be provided to the relevant taxpayers within one month of any such request being submitted, although it should be noted that the objection filing period itself cannot be extended. Any taxpayer objections that are rejected or partially granted will now be subject to an administrative fine of 30% of the relevant tax amount based on an Objection Decision Letter, which is lower than the previous fine of 50%.

The remittance and reporting deadline for stamp duty has now been extended to the 15th day of the month following the end of the relevant tax period. This adjustment also applies to the reporting of stamp-duty collection and remittance, while a notification letter is now required to be submitted to the Directorate-General of Taxes by the 15th day of the month following the end of the relevant tax period.