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Latest Taxpayer Supervision Strategy Under PMK 111/2025

Arunika Consulting Team

At the beginning of this 2026, the tax community’s focus is on the full implementation of PMK Number 111/2025. This regulation becomes the new foundation for fiscal authorities (tax apparatus) in conducting supervision of Taxpayer compliance.

What has changed compared to previous regulations (SE-05/PJ/2022)? Here are the key points.

Risk-Based Approach (Compliance Risk Management)

PMK 111/2025 emphasizes the use of CRM (Compliance Risk Management) as the backbone of supervision. Taxpayers are grouped based on their risk profiles:

  • Low Risk: Will get priority services and minimal supervision.
  • Medium & High Risk: Will become supervision priorities, reminders (SP2DK), to examinations.

The Coretax system automatically processes data from various agencies (ILAP - External Data Integration) to dynamically determine this risk score.

Territorial vs Strategic Supervision

Supervision is now divided into two main focuses:

  1. Territorial Supervision: Focuses on extensification (finding new taxpayers) and field data validation in KPP work areas.
  2. Strategic Supervision: Focuses on large corporate taxpayers, Corporate Groups, and High Wealth Individuals (HWI) with deeper transfer pricing and aggressive tax planning analysis.

Third-Party Data Integration

The main strength of this PMK is the legality of broader third-party data use. Banking data, vehicle ownership, property transactions, to export foreign exchange data are now directly integrated into AR supervision dashboards.

This means, hiding assets or income is becoming increasingly impossible in this 2026.

What Should Taxpayers Do?

  1. Honest Self Assessment: Report as it is. Administrative sanction costs are much more expensive than paying the correct tax.
  2. Review Risk Profile: You can consult with tax consultants to gauge your business risk profile in DGT’s eyes.
  3. Strong Documentation: Keep all transaction evidence. In the era of reverse proof, documents are your main protection.

Want to know your company’s tax risk profile? Arunika Consulting provides Tax Health Check services to mitigate examination risks before it’s too late. Contact us for more information.