SE-8/PJ/2026 sets new timeframes for taxpayer compliance reviews

TaxSE-8/PJ/2026Effective: July 15, 2026

Issued 15 July 2026, this Director General circular consolidates taxpayer compliance supervision into a single risk-based framework aligned with Coretax, replacing four earlier circulars and setting explicit working-day limits for each type of review.

Key points

Issued 15 July 2026, supporting the implementation of PMK 111/2025 on taxpayer compliance supervision.
Aligns the supervision business process with Coretax, and revokes and replaces four earlier circulars.
Covers the full supervision cycle, from planning through evaluation, on a risk-based approach.
Penelitian Formal (formal review): 22 working days, extendable to 44 working days where transfer pricing is involved.
Penelitian Sederhana (simple review): 10 working days.
Penelitian Otomatis (automated review, limited to concrete data): 1 working day.

What this means for Japanese companies

Compliance reviews now run to a published clock, and the transfer pricing extension tells you where DJP expects complexity. If a review letter arrives, the response window is short — know in advance who assembles the explanation and where the supporting records live. Entities with related-party transactions should treat their transfer pricing documentation as review-ready rather than year-end work.

Sources

This page summarises publicly available information for orientation. It is not tax, legal, or accounting advice, and regulations change. Verify against the linked primary sources and contact us before acting on anything here.

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