Regulation Watch · Tax Compliance · Indonesia
PT PMA Tax Representatives Need Level C Authorisation
PMK 44/2026 and PMK 55/2026 require a tax consultant or registered Other Party appointed as a PT PMA's tax attorney to hold Level C classification.
- Published
- PMK 44/2026 promulgated 6 July 2026; PMK 55/2026 promulgated 24 August 2026
- Effective
- PMK 44/2026 from 7 July 2026; PMK 55/2026 from 24 August 2026
- Updated
- 8 September 2026
Who is affected
PT PMA companies, permanent establishments, Indonesian companies, directors, finance teams, tax consultants, and other registered parties formally appointed to exercise a taxpayer's rights or obligations.
Practical impact
A Level B tax consultant cannot provide tax services to a foreign-investment company, permanent establishment, or a person or entity domiciled in a treaty country. Level C covers all individuals and entities. PMK 55/2026 applies the same classification framework to the Surat Keterangan Terdaftar held by a registered Other Party. Before a filing, objection, audit, refund, or other formal tax process, a PT PMA appointing either category as its attorney should verify both active Level C authority and the scope of the special power of attorney. This is distinct from a company's statutory representative acting for the company in that capacity.
Material update to an existing article: PMK 44/2026 was promulgated on 6 July 2026 and, under its own commencement clause, became effective one day later on 7 July. PMK 55/2026 was promulgated and became effective on 24 August 2026. They replace PMK 229/2014 and the former tax-consultant framework under PMK 111/2014 and PMK 175/2022.
The central PT PMA issue is classification. Level A is limited to most individual taxpayers. Level B covers individuals and entities but expressly excludes foreign-investment companies, permanent establishments, and persons or entities domiciled in treaty countries. Level C can serve all individuals and entities. Because PMK 55 applies the classification rules mutatis mutandis to registered Other Parties, PT PMAs should require Level C evidence from either category of formal representative.
PMK 44 also narrows the mechanics of representation. A special power may be electronic or paper, applies to one representative and the defined tax matter, and cannot be delegated. Portal access is a separate step for electronic actions. Existing powers filed before PMK 44 took effect remain usable for their stated scope.
The transition ending 31 December 2026 is important for staff or advisers who are not licensed tax consultants and currently rely only on a brevet certificate or a qualifying accredited tax diploma. It does not remove the need to verify the permitted classification and complete the formal registration or licensing route for appointments after the transition.
Required action
- Verify that every tax consultant formally representing a PT PMA holds an active Level C Tax Consultant Licence, or that an appointed Other Party holds an active Level C Registration Certificate.
- Prepare one special power of attorney for one named representative, stating the specific tax matter and validity period, and grant the required electronic access separately through the Taxpayer Portal.
- Do not treat a representative's staff member who merely delivers or receives documents under an appointment letter as a substitute representative, and do not permit the representative to delegate the authority received from the taxpayer.
- Audit appointments relying only on a brevet certificate or qualifying tax diploma and complete the required licensing or registration before the transition ends.