Companies must take note of a significant policy change under Minister of Finance Regulation No. 44 of 2026 (PMK 44/2026) regarding tax representation. Effective January 1, 2027, in-house corporate tax staff will no longer automatically be permitted to represent their companies in exercising tax rights and fulfilling tax obligations.
To act as a tax attorney (power of attorney in tax matters), company employees must meet the criteria outlined in PMK 44/2026, which includes holding an official Registered Certificate (Surat Keterangan Terdaftar or SKT).
Key Changes to Tax Power of Attorney Rules
PMK 44/2026 replaces the previous regulatory framework that allowed employees to act as tax attorneys under specific conditional criteria.
Under the new regulation, parties eligible for designation as a tax attorney fall into three distinct categories:
- Licensed tax consultants holding a valid practice permit;
- Other Designated Parties (Pihak Lain) who hold an official SKT; and
- Eligible family members in accordance with applicable rules.
Following these amendments, holding an employee status alone is no longer a valid legal basis to represent a company in tax matters.
What Is a Registered Certificate (SKT)?
An SKT is an official document issued by the Minister of Finance or an authorized official, serving as proof that an individual meets the criteria to act as an “Other Designated Party” (Pihak Lain) when representing a taxpayer.
Obtaining an SKT is a mandatory prerequisite for anyone outside of licensed tax consultants and family members to serve as an authorized tax representative.
Transition Period Valid Until Year-End 2026
The government has established a transition window running through December 31, 2026. During this period, corporate tax staff may continue to act as tax attorneys provided they meet previous requirements, such as holding a tax brevet certificate or a formal degree in taxation.
However, once this transitional window closes, those legacy provisions will no longer apply. Starting January 1, 2027, corporate staff seeking to act as tax attorneys must obtain an SKT prior to representation.
Strategic Impact on Businesses
This regulatory shift warrants immediate attention as it directly impacts corporate tax administration.
If a company appoints internal staff who do not meet the new requirements after January 1, 2027, those employees will lack legal standing to represent the company before the Directorate General of Taxes (DGT).
This applies to critical proceedings such as responding to a Request for Explanation on Data and/or Information (SP2DK), undergoing tax audits, or navigating administrative proceedings requiring an official power of attorney.
In such cases, the only parties legally authorized to represent the business will be board members/directors with constitutional signatory authority or qualified representatives compliant with PMK 44/2026.
Recommended Action Items
To prevent administrative disruptions when the rule takes full effect, companies should immediately evaluate their existing tax representation structures. Key recommended steps include:
- Auditing current personnel who regularly handle tax power-of-attorney representation;
- Ensuring eligible staff fulfill the requirements to obtain an SKT well in advance;
- Drafting Special Power of Attorney (SKK) forms aligned with the new regulatory standards; and
- Engaging licensed external tax consultants as a strategic alternative where appropriate.
Proactive preparation during the grace period will ensure a smooth transition and safeguard against operational roadblocks when dealing with the DGT.
Ensuring Regulatory Compliance and Legal Certainty
Appointing a tax attorney extends beyond mere administrative routine; it ensures legal certainty when exercising rights and managing tax liabilities.
A fully compliant tax attorney possesses the legal authority to assist the company across all formal procedures—from data clarifications and audits to tax dispute resolutions under governing laws.
Conversely, relying on non-compliant representatives risks stalling administrative processes and heightening exposure to legal and tax risks.
Conclusion
PMK 44/2026 marks a major shift for organizations that historically relied on internal staff for tax representation. Beginning January 1, 2027, internal tax staff can only serve in this capacity if they have secured a Registered Certificate (SKT).
Businesses should capitalize on the transition period running through the end of 2026 to ensure their appointed representatives meet all formal criteria, guaranteeing seamless tax compliance and uninterrupted operations moving forward.
