Indonesia’s Draft State Budget Law (RUU APBN) for 2027 proposes expanding the Minister of Finance’s authority to examine and audit state revenue, including conducting special audits of tax refund claims involving overpaid taxes.
This provision is outlined in Article 37 of the 2027 State Budget Bill, which was agreed upon at the first-level discussion by the House of Representatives (DPR), the government, and Bank Indonesia on September 24, 2026.
What Is a Special Audit of Tax Refunds?
A tax refund is the process of returning excess tax payments to taxpayers in accordance with applicable regulations. Under the proposed provisions in the 2027 State Budget Bill, the Minister of Finance would be authorized to conduct special examinations or audits of tax refund claims.
This means that applications for refunds of overpaid taxes could be subject to specific audits under procedures that will be established in further regulations.
Joint Audits Are Also Included
In addition to special audits of tax refunds, the 2027 State Budget Bill also includes provisions concerning joint audits, or examinations conducted jointly by relevant authorities, as part of efforts to improve tax compliance.
The policy forms part of an inter-agency cooperation program covering several activities, including:
- Joint analysis.
- Joint tax collection.
- Joint investigations.
- Exchange of intelligence information.
Through this cooperation, coordination between government institutions is intended to support stronger oversight and improve compliance with state revenue obligations.
Has This Regulation Already Taken Effect?
It is important to note that the provisions concerning special audits of tax refunds are still part of the 2027 State Budget Bill. The procedures for special audits and tax refund processes will be further regulated through a Minister of Finance Regulation (Peraturan Menteri Keuangan or PMK).
For comparison, Indonesia’s 2026 State Budget Law did not specifically include the authority to conduct special examinations or audits of tax refund processes as proposed in the 2027 bill.
Businesses should therefore monitor developments in the legislative process and any subsequent implementing regulations before drawing conclusions about how these provisions will be applied.
What Should Taxpayers Prepare?
For companies planning to submit tax refund claims, proper tax administration and documentation are essential. Businesses should ensure that all supporting documents, transaction records, and tax calculations are properly organized and can be substantiated.
These preparations can help companies respond more effectively if an examination is conducted in accordance with applicable regulations.
Rather than waiting until a tax refund claim is submitted, businesses should review the completeness of their tax documentation in advance. Regular tax administration reviews can help minimize errors and prepare companies for potential regulatory changes.
Conclusion
Indonesia’s 2027 State Budget Bill proposes granting the Minister of Finance the authority to conduct special audits of tax refund claims, alongside joint audits as part of broader efforts to strengthen tax compliance and oversight of state revenue.
Although these provisions remain at the draft stage, businesses should begin ensuring that their tax documentation and calculations are properly maintained, particularly if they plan to claim refunds of overpaid taxes.
ADYASTA is ready to assist businesses in understanding developments in Indonesian tax regulations and maintaining well-organized tax administration in accordance with applicable requirements