2025 Tax Audit Rules Tighten Timelines and Transfer Pricing Risks

The Indonesian government, through the Ministry of Finance, issued Ministerial Regulation No 15/2025 (PMK 15/2025) on 17 October 2025. The regulation revises the country’s tax audit framework. The Directorate General of Taxes will enforce the new rules.

PMK 15/2025 shortens the maximum audit period to five months – one month for specific audits, three months for focused audits, and five months for comprehensive audits – versus up to two years under the previous regulation. Auditors must issue a Preliminary Finding and taxpayers have only one month after the Audit Result Notice (SPHP) to submit the requested documents. The rule also interacts with SEMA 2/2024, which limits document acceptance in tax courts, and with PMK 136/2024 that introduces a 15 % global minimum tax for multinational enterprises.

Consequently, companies need to gather all relevant data and documents early and closely monitor transfer‑pricing policies to avoid corrections and penalties. Domestic transfer‑pricing disputes can exceed five years and tie up cash flow. Utilizing a Double Tax Avoidance Agreement (APA) or the Mutual Agreement Procedure (MAP) offers additional risk‑mitigation pathways.