Director General of Taxes Regulation No. 19/2025 (“PER-19”) regarding Deactivation of Access to the Preparation of VAT Invoices for Taxable Entrepreneurs Who Do Not Fulfil its Obligations in Accordance with the Provisions of Tax Laws and Regulations, provides more details regarding the authority of Director General of Taxes (“DGT”) to deactivate taxpayer’s access to prepare VAT invoice which previously has only been briefly mentioned in Article 65 paragraph (1) letter b of Minister of Finance Regulation No. 81/2024.
The objective of this regulation is to encourage compliance with tax administrative requirements and to safeguard the integrity of Indonesia’s digital tax infrastructure.
PER-19 is effective starting 22 October 2025.
This regulation, among other things, explains about:
- The criteria for taxpayers whose access to issue VAT invoices can be deactivated.
- The taxpayer’s right to submit a clarification in order to have its access reactivated.
- The follow-up actions that must be taken by the Tax Office upon receipt of such clarification.
We provide a summary of PER-19 as follows.
CRITERIA FOR TAXPAYER WHOSE ACCESS TO PREPARE VAT INVOICES CAN BE DEACTIVATED
DGT can deactivate taxpayer’s access to issue VAT invoice if a taxpayer does not carry out its obligations to:
A. Withhold or collect all types of taxes that must be withheld or collected for three consecutive months
B. Lodge its Annual Income Tax Return.
C. Lodge its VAT Return for three consecutive months.
D. Lodge its VAT Return for six months or more in one calendar year period
E. Lodge its tax withholding or tax collection slip for all types of taxes that must be withheld or collected, for three consecutive months.
F. Pay its tax payable, which result the taxpayer has tax arrears of at least:
-
- IDR 250,000,000 for taxpayers registered at the Pratama Tax Office (Kantor Pelayanan Pajak Pratama); or
- IDR 1,000,000,000 for taxpayers registered other than at the Pratama Tax Office (Kantor Pelayanan Pajak Pratama)
On which, a warning letter (surat teguran) has been issued, and the taxpayer has not obtained a decision letter granting for installment or postponement of tax payable payment
If the taxpayer fulfills one of the criteria (a to f) listed above, the DGT may deactivate taxpayer’s access to issue VAT invoice and will issue a notice to the taxpayer regarding the deactivation.
CLARIFICATION LETTER AND FOLLOW UP BY TAX OFFICE
If a taxpayer’s access to issue VAT invoice is deactivated, a taxpayer has the right to submit a clarification letter to DGT through the tax office where the taxpayer is registered. The clarification letter should contain explanation and be accompanied by supporting documents to prove that the taxpayer has fulfilled its obligations.
Within five days of receipt of taxpayer’s clarification letter, the tax office must examine the clarification made by a taxpayer and decide whether the tax office approves the clarification and reactivate taxpayer’s access to issue VAT invoice. If tax office does not issue a decision within five days of the receipt, the tax office should reactivate taxpayer’s access to issue VAT invoice.
However, it should be noted that if within five days after the reactivation, the taxpayer is still found not fulfilling its tax obligations (i.e. still meet one of the criteria for deactivation), then the tax office can deactivate taxpayer’s access again.
OTHER MATTERS
Re-activation of access for the preparation of VAT invoices under PER-19, can be carried out as long as the taxpayers is not subject to deactivation of access to VAT Invoice preparation as regulated under Director General of Taxes Regulation No. 9/2025 (“PER-9”) regarding Deactivation of Access to VAT Invoice Preparation in the Context of Handling of Illegal Issuance and/or Use of VAT Invoice.
Disclaimer : This Tax Highlight is intended solely for general informational purposes and should not be construed as professional advice. For tailored and accurate guidance that aligns with your specific circumstances, please contact our professionals.
