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A New Tax Refund Paradigm Under PMK 28/2026

Arunika Consulting Team

Tax refunds are no longer just an administrative waiting game. For many businesses, especially those with tight working capital cycles, a refund can decide whether cash flow remains flexible enough to pay suppliers, fund operations, or keep growth plans moving.

The Directorate General of Taxes article Paradigma Baru Pengembalian Pajak highlights the policy shift introduced by Minister of Finance Regulation No. 28 of 2026. The main idea is clear: Indonesia still wants faster service, but speed will increasingly depend on risk profile, data quality, and verified compliance.

From Administrative Completeness to Risk Profile

PMK 28/2026 replaces the previous framework for preliminary tax overpayment refunds under PMK 39/PMK.03/2018, as amended several times, most recently by PMK 119 of 2024.

This is more than a procedural update. It changes the logic of access.

Previously, preliminary refunds were often viewed through the lens of document completeness. Under the new approach, faster refunds become a form of risk-based fiscal trust. Taxpayers need to show that their data, reporting pattern, and compliance record are consistent enough to justify faster treatment.

In other words, compliance is no longer proven only when a refund claim is filed. It must already be visible in the taxpayer’s history.

Key Numbers Businesses Should Watch

Several practical points deserve attention from business owners and finance teams:

  • Service timelines remain explicit: up to 1 month for VAT and 3 months for income tax.
  • The accelerated VAT preliminary refund threshold for certain taxable entrepreneurs drops from IDR 5 billion to IDR 1 billion.
  • For corporate taxpayers with gross turnover up to IDR 50 billion, the preliminary refund limit remains capped at IDR 1 billion.
  • Low-risk taxable entrepreneurs must meet a substantive condition: at least 80% of business activity should come from the main business activity.
  • The DGT noted that national tax refunds in 2025 reached around IDR 361.2 trillion, up approximately 35.94% from the previous year.

These numbers show why refund policy now matters beyond routine administration. The amount is large enough to affect business liquidity and fiscal control at the same time.

What This Means for Businesses

Businesses that regularly record VAT overpayments, such as exporters, companies with large input VAT, or project-based businesses with long operating cycles, should read this change early.

The question is no longer only, “Are my documents complete?” The better question is, “Does my business profile look consistent, reasonable, and low-risk to the tax system?”

With Coretax, transaction data, tax invoices, payments, returns, and compliance history can be connected more easily. Small mismatches that repeat over time may become risk signals. On the other hand, clean documentation and consistent reporting can become a meaningful advantage.

For import-export businesses, this issue is especially sensitive because VAT refunds can directly affect trade cash flow. If your company operates in this area, our import-export tax service page can help you start mapping VAT, Article 22 income tax, and cross-border documentation risks.

Compliance Becomes Access

One of the strongest messages in PMK 28/2026 is that compliance now functions like access. The cleaner the data and the stronger the compliance record, the greater the chance of receiving more efficient service.

This does not mean every refund will become automatic, or that all claims will become harder. What changes is the way the system sorts taxpayers: who is safe enough for acceleration, and who should be reviewed first.

In practice, finance teams should treat tax refunds as something prepared throughout the tax period, not something assembled only after a tax return shows an overpayment.

A Short Checklist Before Filing a Refund

Before filing a preliminary refund or tax overpayment refund, review these basics:

  1. Make sure input and output VAT invoices match the actual transactions.
  2. Reconcile purchase, sales, payment, and supporting contract data.
  3. Check whether the main business activity is clearly reflected in bookkeeping and tax reporting.
  4. Review late returns, repeated amendments, or outstanding tax liabilities that may affect the risk profile.
  5. Prepare supporting documents before the claim is filed, not only after a clarification request arrives.
  6. Review large accounts that may trigger questions from the tax office.

For companies that want to understand their position before filing, a tax health check can help identify gaps between accounting records, tax returns, and data that may be visible to the DGT.

Conclusion

PMK 28/2026 points to a new direction in Indonesian tax administration: faster for taxpayers with clean data, more selective for riskier profiles, and increasingly dependent on integrated systems.

For business owners, the lesson is simple. A tax refund does not start when the application is submitted. It starts with how the business records transactions, issues tax invoices, files returns, and keeps data consistent throughout the year.

Need a review before filing a tax refund claim? Arunika Consulting can help assess document readiness, identify risk signals, and prepare corrective steps before the process begins. Contact us for an initial consultation.

This article is educational and refers to a publication by Indonesia’s Directorate General of Taxes. For specific tax decisions, consult a certified tax consultant.