Under Circular Letter of the Director General of Taxes No. SE-8/PJ/2026 (SE 8/2026), tax authorities can now directly propose concrete data for a tax audit. Issued on July 15, 2026, taxpayers must grasp this new rule to mitigate costly risks, such as increased tax liabilities and heightened compliance costs.
What Constitutes “Concrete Data”?
SE 8/2026 defines concrete data as ready-to-use tax data that requires only basic verification by the Directorate General of Taxes (DGT) to calculate the tax liability owed.
Meanwhile, Article 4, Paragraph (2) of Minister of Finance Regulation No. 15 of 2025 (PMK 15/2025) specifies three categories of concrete data that can serve as the basis for a tax audit:
- Tax Invoices approved in the DGT’s IT system but not reported (or omitted) by the taxpayer in their periodic Value Added Tax (VAT) return.
- Withholding/Collection Certificates for Income Tax that have not been reported by the issuer in their periodic Income Tax return.
- Transaction Records or Tax Data that can directly be used to calculate tax liabilities.
Article 2, Paragraph (2) of Director General of Taxes Regulation No. 18 of 2025 (PER 18/2025) details the specific transaction records used to calculate tax liabilities:
- Excess VAT input carrying over to the next period without a corresponding overpayment from the preceding VAT return.
- Recalculation of input tax deducted from output tax by taxpayers who are ineligible to use input tax crediting guidelines for taxable persons engaging in both taxable and non-taxable supplies.
- Unpaid or underpaid prepaid VAT.
- Misuse or non-compliant use of tax incentives.
- Non-compliant crediting of input tax.
- Unreported or underreported income based on withholding data in the DGT system, or errors arising from the use of net income calculation norms.
- Data or information derived from binding legal tax assessments, decisions, or final court rulings (inkracht) that can directly determine unreported or underreported tax liabilities.
- Data or information for which a Request for Explanation on Data and/or Information (SP2DK) was issued and agreed upon by the taxpayer for follow-up, but remained unfulfilled by the deadline.
Concrete Data in Tax Supervision and Auditing
SE 8/2026 fast-tracks the supervision of concrete data to prevent statutory limitation periods from expiring—set at 5 years from the time tax becomes due, or from the end of the tax period, fractional tax year, or tax year.
The regulation outlines specific supervisory responses based on the remaining time before the statute of limitations expires:
- 12 Months or Less Remaining: The data is placed on the Supervision Priority List.
- 90 Days or Less Remaining: The DGT may immediately recommend a tax audit without issuing an SP2DK first.
- Between 90 Days and 12 Months Remaining: The standard SP2DK process applies.
Under PMK 111/2025, taxpayers have up to 14 days to respond or provide clarification, with an extendable option of up to 7 days. An SP2DK can lead to filing or amending tax returns (Annual or Periodic), escalating the concrete data for audit, or closing the case if no non-compliance is found.
Tax Audits on Concrete Data
Article 3 of PER 18/2025 clarifies that tax audits based on concrete data fall under the category of Specific Audits, which carry a streamlined 1-month examination period.
PMK 15/2025 defines a Specific Audit as an examination designed to test tax compliance specifically and straightforwardly on one or a few line items in tax returns, taxable object returns, specific data, or designated tax obligations.
Furthermore, Article 6, Paragraph (4) of PMK 15/2025 stipulates that audits on concrete data must be completed within 20 business days—comprising 10 business days for testing and 10 business days for closing conferences and reporting.
Conclusion
The rollout of SE 8/2026 presents a new challenge for taxpayers. Under this expedited framework, concrete data with 90 days or less remaining on its statute of limitations can bypass the SP2DK clarification stage entirely and head straight to an audit proposal.
To manage this risk, taxpayers should strengthen internal compliance by conducting periodic internal audits and tax reconciliations—focusing particularly on tax invoices, withholding certificates, and accounting ledgers. Gathering and maintaining comprehensive supporting documentation will be critical to mitigating the impact of Specific Audits.
