Amid the buzz of the Coretax transition, another major shift is changing how Indonesia competes for foreign investment: the Global Minimum Tax (GMT), the result of the OECD/G20 Pillar Two consensus under the BEPS (Base Erosion and Profit Shifting) framework. Its legal basis in Indonesia is MoF Regulation Number 136 of 2024, stipulated December 31, 2024, and 2026 marks an important milestone: its final enforcement mechanism — UTPR — is now officially in effect, completing two mechanisms that have already been active since 2025.
Who's covered
GMT targets corporate taxpayers that are part of a multinational enterprise (MNE) group with global consolidated revenue of at least €750 million (roughly Rp12.7 trillion), reached in at least 2 of the last 4 fiscal years. If that group's effective tax rate (ETR) in a given jurisdiction falls below 15%, a top-up tax is imposed to cover the shortfall.
Three GMT enforcement mechanisms
| MECHANISM | HOW IT WORKS | EFFECTIVE IN INDONESIA |
|---|---|---|
| DMTT (Domestic Minimum Top-up Tax) | Indonesia itself collects the top-up tax on the domestic profit of low-ETR entities, rather than letting another country collect it | January 1, 2025 |
| IIR (Income Inclusion Rule) | The MNE group's parent entity pays top-up tax on subsidiaries with an ETR below 15% | January 1, 2025 |
| UTPR (Undertaxed Payment Rule) | The final backstop — applied if the top-up tax isn't collected via IIR, for instance because the parent's country doesn't apply this rule | January 1, 2026 |
There's also STTR (Subject to Tax Rule), a tax-treaty-based mechanism allowing the source country to tax certain payments (interest, royalties, services) taxed below 9% in the recipient country.
Why 2026 is the crucial year
With UTPR taking effect January 1, 2026, Indonesia's Pillar Two framework is now complete across three layers. This year also marks an important point in terms of real financial obligations: estimated top-up tax payment for tax year 2025 is due no later than December 31, 2026. Meanwhile, formal reporting — the GloBE Information Return and Annual GloBE Income Tax Return — has a longer window: for tax year 2025 (the first year of coverage), reporting gets relief of up to 18 months after year-end (due no later than June 30, 2027); for tax year 2026 onward, the normal 15-month window applies (due no later than March 31, 2028).
Impact on existing tax incentives
This is the part that changes business calculations the most. Incentives like tax holidays, tax allowances, and Special Economic Zone (SEZ) facilities work by reducing tax paid — which also lowers ETR. If ETR falls below 15% because of that incentive, the top-up tax will still be collected — the question just shifts to who collects it: Indonesia itself via DMTT, or the parent company's home country via IIR.
A shift in incentive design: from Tax Holiday to QRTC
Recognizing this, the government is steering incentive design toward an instrument more resilient to GMT: the Qualified Refundable Tax Credit (QRTC). The fundamental difference lies in GloBE accounting treatment — a tax holiday directly reduces the numerator in the ETR formula (drastically lowering ETR), while QRTC is treated as additional income that doesn't reduce tax paid in the ETR formula. The result: a company's ETR stays close to or above 15%, while the company still receives a financial benefit in the form of a cash refund or tax credit.
The old tax holiday facility was extended until December 31, 2025 to provide legal certainty for investors with pending applications. Starting 2026, the new QRTC framework is expected to apply more fully, strategically directed toward encouraging research and development activities and other long-term economically impactful activities.
Rising compliance burden
For covered business groups, implementing MoF Reg. 136/2024 adds significant calculation complexity — from computing GloBE profit, ETR per jurisdiction, to the top-up tax if ETR falls below 15%. International tax practitioners note that these calculations involve many detailed adjustments requiring deep study, and even the tax authority itself is still deepening its understanding of implementation together with taxpayers and consultants.
Steps for covered business groups to take
- First confirm whether your group is actually covered — check the group's global consolidated turnover over the last 4 fiscal years against the €750 million threshold.
- Map ETR per jurisdiction where the group operates, particularly entities enjoying significant tax incentives in Indonesia.
- Re-evaluate the value of incentives currently or soon to be received — make sure the incentive still provides real benefit after accounting for potential top-up tax from DMTT or IIR.
- Prepare reporting infrastructure for the GloBE Information Return well before the deadline, given the complexity of data across jurisdictions.
- Consult on group restructuring or profit localization early if relevant — not as a last-minute reaction as the reporting deadline approaches.
GMT isn't just a technical tax regulation update — it's a shift in international tax architecture that changes the fundamental calculation behind why multinational companies choose to invest in a given country. For covered business groups, early readiness and transparent documentation are key to navigating this new chapter.
Disclaimer: This article was prepared as general information as of July 7, 2026 and does not constitute tax advice for any specific case. Tax regulations are subject to change. For guidance on your specific business situation, please consult the Sentary Consulting team or a registered tax consultant.