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PER-12/PJ/2026: Revised Tax Return Amendment Rules Clarify the Treatment of Artificial Underpayment

Artificial Underpayment

Artificial Underpayment

The Directorate General of Taxes (DGT) has issued PER-12/PJ/2026 to update the previous regulation, PER-11/PJ/2025. This regulation aims to provide greater certainty for taxpayers when amending their tax returns and to prevent the emergence of artificial tax underpayments that do not represent new tax liabilities.

The provisions cover amendments to Article 21/26 Income Tax Returns, Unified Income Tax Returns, Monthly Value Added Tax (VAT) Returns, and Annual Tax Returns.

What Has Changed Under the Revised Tax Return Amendment Rules?

One of the key aspects of this regulation is the calculation mechanism applied when taxpayers amend their tax returns, particularly in relation to the underpayment or overpayment status reported in the original return.

Previously, VAT calculations in amended tax returns still took into account the underpayment or overpayment position reported in the original return. This could potentially result in an apparent tax underpayment even when the taxpayer was simply correcting a previously submitted report.

Through PER-12/PJ/2026, the calculation mechanism has been clarified by taking into account VAT that has already been paid, as well as overpayments that have been refunded or processed in accordance with the applicable provisions.

As a result, the amendment process is expected to better reflect the taxpayer’s tax position based on the corrected return, while reducing confusion arising from differences between the original and amended calculations.

A Practical Example: Amending a Monthly VAT Return

To better understand the implications of this change, consider the following example provided in the explanatory material for PER-12/PJ/2026.

A company files its December 2026 Monthly VAT Return, reporting a VAT overpayment of IDR 200,000. However, on February 20, 2027, the company amends its return after determining that the correct overpayment amount is only IDR 150,000.

Under the previous mechanism: The IDR 50,000 difference could potentially be treated as an underpayment if the company did not select the option to replace the previous tax return.

Under the revised regulation: The overpayment reported in the amended return becomes IDR 150,000, reflecting the corrected figures.

This example highlights the importance of an appropriate calculation mechanism to ensure that adjustments to a tax return do not automatically create the perception of an additional tax liability.

What Are the Benefits for Taxpayers?

The revised provisions under PER-12/PJ/2026 are expected to provide several benefits for taxpayers, including:

Conclusion

PER-12/PJ/2026 represents an update to the tax return amendment framework intended to provide greater certainty for taxpayers. By clarifying the calculation mechanism, the regulation is expected to reduce the risk of artificial tax underpayments arising from differences between original and amended tax returns.

Ultimately, amending a tax return should help taxpayers correct their tax reporting accurately, rather than create confusion due to apparent underpayment calculations.

Need assistance with understanding or amending your company’s tax returns?

ADYASTA Consulting is ready to help your business navigate tax regulations and manage its tax compliance obligations more effectively.

Visit www.adyasta.com to learn more about our tax consulting and business advisory services.

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