Global minimum tax: every Indonesian entity of an in-scope multinational group must register as a GloBE taxpayer by 30 September 2026 — and no one can do it for them

If your group's consolidated revenue reaches EUR 750 million, Indonesia's global minimum tax rules now come with an administrative deadline that is a week away. Under PER-6/PJ/2026 — the Director General of Taxes' implementing regulation for PMK 136/2024, in force since 4 May 2026 — each constituent entity in Indonesia must apply through Coretax to have GloBE taxpayer status added to its own tax record, no later than nine months after the end of the first GloBE year. For groups whose first GloBE year was calendar 2025, that means 30 September 2026. DJP officials made the point again on 22 September that this cannot be delegated: every constituent entity registers itself, there is no lead entity, and the later GloBE return cannot be filed by one entity on behalf of the others. If a company does not apply, DJP can assign the status ex officio after an administrative review. DJP has said thousands of entities are expected to fall in scope.

Key points

• Who is in scope: constituent entities of multinational groups whose ultimate parent's consolidated financial statements show annual revenue of at least EUR 750 million in at least two of the four fiscal years before the GloBE year (PMK 136/2024). The minimum effective rate is 15%, applied through the income inclusion rule (IIR) and the domestic minimum top-up tax (DMTT) from 2025, and the undertaxed payment rule (UTPR) from 2026.
• The deadline: an application to add GloBE taxpayer status must be filed no later than nine months after the end of the first GloBE year — 30 September 2026 for a group whose first GloBE year was calendar 2025. It is filed electronically by each entity through the Coretax taxpayer portal.
• No lead entity: DJP tax educators restated on 22 September that "all group members must register, not just one — there is no lead entity," and that the GloBE return likewise cannot be filed by one constituent entity on behalf of several.
• If you do not apply: DJP can add the GloBE taxpayer status ex officio (secara jabatan) based on its own administrative review, and says it can examine both registered and unregistered entities that appear to be in scope.
• What comes after registration, per PER-6/PJ/2026: top-up tax under IIR, DMTT or UTPR is paid by the end of the GloBE tax year — 31 December 2026 for the 2025 GloBE year — using billing code 411618 with payment-type codes 610 (IIR), 620 (UTPR) and 630 (DMTT), and payment comes before filing.
• Returns: the GloBE annual return is due four months after the end of the GloBE tax year, extendable by two months in the first year; the GloBE Information Return (GIR) or a notification is due 15 months after the end of the GloBE year, and 18 months for the first year. For the 2025 GloBE year, reporting lands on 30 June 2027.
• Scale: DJP has said thousands of entities are expected to need GloBE taxpayer status. Being in scope is a group-level test — an Indonesian subsidiary that is small locally is still a constituent entity if the group clears the threshold.

Sources

• Direktorat Jenderal Pajak — PER-6/PJ/2026, Tata Cara Pelaksanaan Hak dan Pemenuhan Kewajiban Pajak Minimum Global Berdasarkan Kesepakatan Internasional (established 4 May 2026)
• JDIH Kemenkeu — PMK 136 Tahun 2024, Pengenaan Pajak Minimum Global Berdasarkan Kesepakatan Internasional (promulgated 31 December 2024)
• DDTCNews — Semua Entitas Harus Daftar WP GloBE dan Lapor SPT, Tak Bisa Diwakilkan (17:00 WIB, 22 September 2026; DJP Jakarta Khusus tax educators)
• DDTCNews — DJP: WP GloBE Harus Lakukan Pendaftaran Paling Lambat September 2026
• DDTCNews — PER-6/PJ/2026 Terbit, Begini Lini Masa Pelaporan Pajak Minimum Global (registration 30 September 2026, payment 31 December 2026, reporting 30 June 2027)
• Ortax — DJP Wajibkan Grup PMN Ajukan Status Wajib Pajak GloBE Paling Lambat September 2026 (ex officio assignment if no application)
• Pajakku — DJP Atur Tata Cara Pelaporan Pajak Minimum Global lewat PER-6/PJ/2026 (Coretax filing, payment codes, return deadlines)
• DDTCNews — DJP Ungkap Ada Ribuan Entitas yang Wajib Berstatus WP GloBE