The Government has officially issued Minister of Finance Regulation (PMK) Number 28 of 2026, which governs the acceleration of the preliminary refund process for tax overpayments (restitution). This policy serves as a strategic step to improve the quality of tax services while providing certainty for taxpayers.

The regulation affirms that the preliminary refund mechanism is carried out through a research process rather than an audit. This approach is considered capable of reducing processing time without compromising due diligence, ensuring data validity is maintained and oversight functions continue to operate optimally.

Taxpayers may re-submit applications for designation as certain criteria taxpayers from 1 June 2026 to 10 June 2026. Designation applications will be processed within 30 days from the date the application is submitted.

Certain Criteria

Article 3 of PMK 28/2026 stipulates that taxpayers meeting certain criteria are eligible for accelerated restitution of Income Tax (PPh) and Value Added Tax (VAT). The following conditions constitute the certain criteria:

1. Timely submission of Tax Returns (SPT);
2. No outstanding tax arrears for any type of tax, except for tax arrears for which an instalment or deferred payment permit has been granted;
3. Financial statements have been audited by a public accountant or a government financial supervisory body with an unqualified opinion (WTP) for 3 consecutive years; and
4. Has never been convicted of a criminal offence in the field of taxation based on a court decision that has obtained permanent legal force within the last 5 years.

Taxpayers may obtain the status of a certain criteria taxpayer by submitting an application to the Director General of Taxes (Dirjen Pajak) electronically through Coretax no later than 10 January. If electronic submission is not possible, the taxpayer may submit the application in person or by post, courier company, or parcel service to the Tax Service Office (KPP), tax service, outreach, and consultation office (KP2KP), or other locations designated by the Director General of Taxes.

In support of the implementation of PMK 28/2026, taxpayers need to ensure that all administrative and substantive requirements have been properly fulfilled prior to submitting the application for certain criteria designation. Accuracy in data submission and completeness of documents are key factors in facilitating the research process by the tax authority.

In this regard, Adyasta is ready to assist taxpayers in conducting compliance reviews, preparing documents, and providing assistance throughout the process of applying for certain criteria designation through the Coretax system. Backed by experienced professionals in the field of taxation, Adyasta is committed to providing precise, measurable, and regulatory-compliant solutions.