In depth

Criteria of income tax collectors

• E-commerce marketplaces that use escrow accounts to deposit income received or earned by domestic sellers may be appointed if they meet one or both of the following thresholds:

1. The transaction value with service users in Indonesia exceeds IDR 600 million within 12 months or IDR 50 million within one month.
2. The number of users accessing the platform from Indonesia exceeds 12,000 within 12 months or 1,000 within one month.

Appointment procedure

• The DGT will appoint e-commerce marketplaces that have met the criteria, through issuance of a DGT decision. The appointment as an income tax collector will apply from the beginning of the month after the month in which the DGT decision is made.
• E-commerce marketplaces that have not been appointed as income tax collectors but choose to be appointed may submit a notification to the DGT either in person at the tax office where the taxpayer is registered, or online through the taxpayer portal or other websites integrated with the DGT administration system.
• If an e-commerce marketplace no longer meets the criteria to be appointed as an income tax collector, the DGT may revoke the appointment either ex officio or based on a notification submitted by the e-commerce marketplace. The DGT will conduct an examination and issue a formal decision regarding the revocation of the appointment.
• Overseas e-commerce marketplaces that are appointed as income tax collectors will be issued a Tax Identification Number for Indonesian tax administration purposes. Domestic e-commerce marketplaces appointed as income tax collectors will use their existing registered Tax Identification Number.
• If the DGT revokes the appointment of an overseas e-commerce marketplace as an income tax collector, the associated Tax Identification Number must be removed ex officio through a formal examination process.

Collection of income tax Article 22

• Article 22 Income Tax withheld by e-commerce marketplaces may be credited against the current year’s tax liability or treated as part of the final income tax settlement for domestic sellers, provided the sellers have submitted their name and Taxpayer Identification Number (NPWP) or national identity number (NIK) registered in the DGT system, which must be included in the proof of Article 22 Income Tax collection.
• The obligation to collect, pay and report Article 22 Income Tax for fiscal year 2025 must be implemented no later than one month from the time of appointment as income tax collectors.

Actions to consider

Businesses need to assess the possibility that they will be subject to these new tax obligations, and should monitor further implementing regulations to ensure proper classification as income tax collectors.

In cases where they may be subject to the new obligations, businesses may also need to prepare their systems to accommodate the potential new tax obligations and begin to socialize this potential new tax obligation to their merchants.

Download alert here.

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Ria Muhariastuti, Senior Tax Specialist, and Harizka Rizal, Tax Specialist have contributed to this legal update.

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