Indonesia Issues Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements
May 13, 2026
On May 4, 2026, Indonesia Issued Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements.
This is a new Safe Harbour included in the January 2026 OECD Side-by-Side Tax Package (see: Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package).
Side-by-Side (SbS) Safe Harbour
The SbS Safe Harbour excludes an MNE group from the IIR and UTPR (not QDMTT) where its UPE is located in a qualifying SbS jurisdiction. A qualifying SbS jurisdiction is a jurisdiction that has an eligible domestic tax regime and an eligible worldwide tax regime (generally required to be in place before January 1, 2026) as well as providing a FTC for QDMTTs.
Various conditions are required to be met for a tax system to qualify as an eligible domestic tax system or an eligible worldwide tax regime (eg for an eligible domestic system its statutory nominal CIT rate is at least 20%), however in both cases there must not be a material risk that the GloBE ETR would be below 15%.
Whether a jurisdiction qualifies as a qualifying SbS regime will be determined by the OECD and the jurisdiction will be included in the Central Record (similar to how DMTTs that qualify as QDMTTs etc are). To date only the USA is recognised by the OECD as a qualifying SbS regime.
The SbS Safe Harbour will apply for Fiscal Years from January 1, 2026.
UPE Safe Harbour
The UPE Safe Harbour is similar to the SbS Safe Harbour but only applies to exclude an MNE group from the UTPR on profits located in the UPE jurisdiction. However to qualify a jurisdiction only needs to have an eligible domestic tax regime (not an eligible worldwide tax regime as required for the SbS Safe Harbour).
As with the SbS Safe Harbour, Qualified UPE Regimes will be listed in the OECD Central Record and this Safe Harbour will apply from January 1, 2026.
On May 4, 2026, Indonesia Issued Regulation PER-6/PJ/2026 on Pillar Two Administrative Requirements.
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On May 6, 2026, Switzerland opened a consultation on amendments to the Swiss Minimum Taxation Ordinance, to delay the Swiss application of the OECD January 2025 Administrative Guidance on Article 9.1 of the GloBE Model Rules for one year.
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