Indonesia awaits two regulations before confirming 0% tax on SOE restructuring
Tax chief Bimo Wijayanto said existing tax codes could be revised, leaving the treatment of state-owned enterprise restructuring unconfirmed.
Indonesia’s Directorate General of Taxes is awaiting a government regulation and a finance ministerial regulation before confirming a 0% final income tax incentive for restructuring transactions involving state-owned enterprises (SOEs).
Director General of Taxes Bimo Wijayanto told reporters on 15 October 2026 that the government must first examine the government regulation. He did not confirm whether the tax treatment would follow descriptions already included in tax regulation PER-12/PJ/2026, and said the relevant tax codes could be revised.
PER-12/PJ/2026 lists several categories with a 0% final income tax rate, but their inclusion does not confirm that the incentive will be implemented as described. The listed categories include:
- 28-408-02: Transfers of shares as gifts to organise the ownership structure of SOEs.
- 28-408-03: Receipt of shares as gifts to organise the ownership structure of SOEs.
- 28-408-04: Non-cash share buybacks or withdrawals in restructuring transactions involving SOEs and their subsidiaries that may use book value.
- 28-408-05: Non-cash reductions in the nominal value of shares in restructuring transactions involving SOEs and their subsidiaries that may use book value.
- 28-408-06: Transfers and acquisitions of business lines involving cash in restructuring transactions involving SOEs and their subsidiaries that may use book value.
- 28-408-07: Gains from debt forgiveness received or obtained by restructuring entities as part of the restructuring of SOEs and their subsidiaries.
