Indonesia Issues Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements

On May 4, 2026, Indonesia issued Regulation PER-6/PJ/2026 on Pillar Two Administrative requirements. This includes  GloBE taxpayer status, annual GloBE returns, DMTT and UTPR returns, GIR filing, notifications, payment codes, post-filing adjustments, supervision, audits and dispute procedures. 

GloBE taxpayer status: registration

A covered taxpayer must submit an application to be registered as a GloBE taxpayer no later than nine months after the end of its first GloBE imposition year, through the Indonesian tax portal. If the taxpayer does not apply, the tax office may add the GloBE status ex officio based on administrative research.

Once a taxpayer has GloBE status, PER-6’s return, notification, payment and audit mechanics become practically unavoidable. Conversely, failure to register does not prevent the DGT from monitoring an entity that it considers in scope; PER-6 expressly contemplates supervision of taxpayers that have not yet added GloBE status.

The annual returns: GloBE, DMTT and UTPR

PER-6 introduces an annual return framework for the global minimum tax. The annual GloBE income tax return package includes the GloBE Annual Income Tax Return, DMTT Annual Income Tax Return and UTPR Annual Income Tax Return, with attachments covering IIR, DMTT, UTPR, GloBE income or loss, adjusted covered taxes, shipping exclusions, substance-based income exclusion, additional current top-up tax and DMTT allocation.

An Indonesian ultimate parent entity is expected to complete the GloBE return components relevant to IIR, UTPR and DMTT. Non-UPE Indonesian GloBE taxpayers must address DMTT, and may have UTPR reporting obligations where UTPR top-up tax is allocated to them.

The filing deadline is four months after the end of the GloBE tax year. PER-6 allows a filing extension of up to two months for the first GloBE year, and requires payment evidence to be attached where there is an underpayment.

GIR and notification obligations