The Minister of Finance has introduced new tax audit regulations through Minister of Finance Regulation (PMK) No. 15/2025 on Tax Audits. This regulation provides further guidance on Government Regulation (PP) No. 50/2022 regarding the Procedures for Exercising Taxpayer Rights and Fulfilling Tax Obligations. With the issuance of PMK 15/2025, the previous regulations under PMK 17/2013, as last amended by PMK 18/2021, have been revoked.

Understanding Tax Audits

A tax audit is a series of activities aimed at collecting and analyzing data, information, and/or evidence in an objective and professional manner based on audit standards. The primary purpose of an audit is to assess taxpayer compliance in fulfilling tax obligations, as well as to serve other purposes within the scope of tax regulations.

With the implementation of PMK 15/2025, several key changes distinguish it from previous tax audit regulations. These changes include:

1. New Classification of Tax Audits

Previously, tax audits were categorized into Field Audits and Office Audits. Under PMK 15/2025, audits are now classified into three types:

• Comprehensive Audit – A full-scope audit examining all items in the Tax Return (SPT) or Tax Object Return.
• Focused Audit – A targeted audit assessing one or more specific items in the Tax Return.
• Specific Audit – A limited-scope audit reviewing certain tax obligations, data, or specific tax items in a simplified manner.

This reclassification also affects the timeframes for completing audits.

2. Adjustments to Audit Timeframes

Previously, audit time limits varied:

• Field Audits had a maximum period of 6 months
• Office Audits had a maximum period of 4 months, with possible extensions in certain conditions.

Under PMK 15/2025, the audit duration is determined by the audit type:

Audit Type	Maximum Duration
Comprehensive Audit	5 Months
Focused Audit	3 Months
Specific Audit	1 Months

3. Shorter Timeframe for Responding to Audit Findings

Under previous regulations, taxpayers had 7 working days to submit a written response to the Tax Audit Findings Report (SPHP), with an option for a 3-day extension.

With PMK 15/2025, the response period has been reduced to 5 working days, with no extension allowed. This presents a new challenge for taxpayers, requiring faster preparation of their responses.

4. Shorter Final Review Period (PAHP)

The Final Review of Audit Findings (PAHP) process has also been shortened under PMK 15/2025.

• Previously, the review period lasted up to 2 months, from the date the SPHP was issued to the taxpayer until the issuance of the Final Audit Report (LHP).
• Now, the entire process must be completed within 30 working days.

Key Takeaways

With the implementation of PMK 15/2025, the government aims to enhance the efficiency and effectiveness of tax audits through:

• Clearer classification of audit types
• Shorter audit timeframes
• Reduced response time for taxpayers
• Streamlined audit completion deadlines

While these changes are designed to provide greater legal certainty and faster tax administration, they also demand greater preparedness from taxpayers to ensure compliance with the new rules.

audit-timeframe-reduction , pmk-152025 , tax-audit-procedures , taxpayer-response-deadline