Tax overpayments usually can only be cashed out after a full audit — a process that can take months. But for certain taxpayers, there's a faster route called an advance refund (pengembalian pendahuluan): the overpaid amount is refunded first based on an administrative review, not a full audit. This route has just been reorganized through MoF Regulation Number 28 of 2026, stipulated April 29, 2026 and effective May 1, 2026 — replacing MoF Reg. 39/2018 and all its amendments.
Three categories of eligible recipients
MoF Reg. 28/2026 divides eligible taxpayers into three groups, each with different requirements.
1. Taxpayers with Specific Criteria (Article 17C of the General Tax Provisions Law)
This category is for long-term compliant taxpayers, and the requirements are now much stricter than before:
- Timely filing of Annual Tax Returns for the past 3 years, as well as January–November Periodic Returns for the latest year
- No outstanding tax arrears of any kind (except those under an approved installment/deferral arrangement)
- No history of late tax payment in the past 5 years
- Financial statements audited by a public accountant with an unqualified (clean) opinion for 3 consecutive years — and not the result of a restatement due to error correction or data manipulation
- No fiscal profit/loss correction exceeding 5% based on a prior audit
- The auditing public accountant must not have provided audit services to the same taxpayer for more than 5 consecutive years
- No criminal tax conviction in the past 5 years
Applications for this status are submitted electronically through the taxpayer portal, no later than January 10 each year.
2. Taxpayers Meeting Specific Requirements (Article 17D of the General Tax Provisions Law)
This category doesn't require special designation from the DGT — taxpayers simply tick the advance refund option when filing their return. What's changed from the old rule is a more detailed set of value thresholds:
| TAXPAYER TYPE | THRESHOLD |
|---|---|
| Individual, not running a business/independent profession | No value limit on overpayment |
| Individual, business owner/independent professional | Overpayment max Rp100 million |
| Corporate entity | Turnover max Rp50 billion/year, overpayment max Rp1 billion |
| Taxable Entrepreneur (VAT refund) | Supply value max Rp4.2 billion, VAT overpayment max Rp1 billion |
3. Low-Risk Taxable Entrepreneurs (Article 9(4c) of the VAT Law)
This category covers listed/public companies, state/regional-owned enterprises, authorized customs partners, authorized economic operators (AEO), manufacturers, major pharmaceutical wholesalers, certain medical device distributors, and majority-owned subsidiaries of state enterprises. Additional requirements:
- Timely filing of periodic VAT returns for the past 12 months
- Not currently under a preliminary evidence audit or criminal tax investigation
- No criminal tax conviction in the past 5 years
- At least 80% of total supply value for the relevant tax period must come from specific activities — export of tangible/intangible goods, export of services, or supply to a VAT collector
The process: review, not a full audit
The philosophical core of this regulation is that advance refunds are granted through an administrative review mechanism — the DGT validates the correctness of calculations, matches withholding/collection evidence, and confirms payment validity — rather than a full field audit. For low-risk PKPs, the DGT must issue an Advance Refund Decision Letter (SKPPKP) within 1 month of receiving the application.
But this convenience doesn't remove oversight. Taxpayers who've already received an advance refund can still be audited later. If the audit finds an underpayment, the DGT can still issue an underpayment assessment along with the applicable sanctions.
Overpayments that can be rejected
MoF Reg. 28/2026 also clarifies what does not count as a valid overpayment, including: differences from rounding in the administrative system, overpayment amounts stemming from government-borne income tax, and taxpayer errors in entering tax credits or withholding evidence.
What you need to prepare
- Consistent audited financial statements. If you're aiming for Specific-Criteria status, a clean opinion for three consecutive years is now an absolute requirement — not just a nice-to-have.
- Routine reconciliation of withholding evidence and tax invoices, since the validity of NTPN payment codes and credited tax invoices is now the key determinant of application approval.
- Re-check your old status. Don't assume your Specific-Criteria or Low-Risk PKP status from the previous rule still applies — apply for re-designation promptly if you still qualify.
- Identify which category best fits your business profile — for most MSMEs and mid-sized entities, the Article 17D route with its specific value thresholds is usually more realistic than the Specific-Criteria route, which requires a three-year clean audit history.
Disclaimer: This article was prepared as general information as of July 6, 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.