Indonesia Officially Adopts the Global Minimum Tax: What You Need to Know About PMK-136/2024
Business Opportunities
April 2, 2025 - TaxPrime (Persekutuan Soewito, Fajar dan Rekan)In this article, member firm TaxPrime explains Indonesia’s official adoption of the Global Minimum Tax (GMT) through PMK-136/2024. Effective from 1 January 2025, this regulation brings the country in line with the OECD/G20 Pillar Two GloBE Rules, requiring large multinational enterprise groups to meet a 15% minimum effective tax rate across jurisdictions. The article outlines who’s affected, how the tax is calculated, and the transitional safe harbor provisions designed to ease initial compliance.
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Indonesia has officially implemented the Global Minimum Tax (GMT) under PMK-136/2024, effective 1 January 2025, aligning with the OECD/G20 Pillar Two GloBE Rules. This regulation ensures that Multinational Enterprise (MNE) Groups meet a minimum Effective Tax Rate (ETR) of 15% in every jurisdiction where they operate. The scope of GMT applies to MNE Groups with consolidated revenue exceeding EUR 750 million in at least two of the four preceding fiscal years. If an MNE’s ETR falls below 15%, a top-up tax is imposed, following a priority order: Qualified Domestic Minimum Top-Up Tax (QDMTT) in the jurisdiction where the entity operates, followed by the Income Inclusion Rule (IIR) at the Parent Entity’s jurisdiction, and finally, the Undertaxed Profits Rule (UTPR) for other jurisdictions. To ease compliance in the first three years, Indonesia has introduced transitional safe harbor provisions, allowing entities to qualify for exemptions based on CbCR data through three simplified tests.
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TaxPrime (Persekutuan Soewito, Fajar dan Rekan)
TaxPrime is a homegrown firm with multidisciplinary expertise and extensive industry knowledge, offering comprehensive solutions to help businesses navigate Indonesia's dynamic regulatory landscape. Supported by over 240 professionals, including 27 former officials from the Directorate General of Taxes and Customs & Excise, TaxPrime delivers strategic insights across various business stages, from market entry and operational optimization, to dispute resolution and business transformation. Its client-centric approach combines deep local expertise with a global outlook, enabling tailored solutions that align with sustainable and responsible practices, while driving long-term business growth.
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