Indonesia's Directorate General of Taxes (DGT) has formalised its supervisory powers over multinational enterprise groups subject to the GloBE rules through Director General of Taxes Regulation Number PER-6/PJ/2026. The regulation confirms that the DGT may supervise qualifying taxpayers whether or not they have formally registered their GloBE status, and introduces an ex officio registration mechanism for those that fail to self-identify.
Scope of supervision
Article 23(3) of PER-6/PJ/2026 sets out the legal basis for DGT oversight. Supervision is to be conducted on the basis of data and information already held by the DGT, meaning the authority does not need to wait for a taxpayer to come forward before it can act. For taxpayers that have completed the status addition process, supervision covers the full range of GloBE compliance obligations: filing the annual income tax return in the GloBE context, making the required tax payments, submitting notifications, and filing the GloBE Information Return (GIR).
For taxpayers that have not yet registered, the DGT's supervisory remit extends to assessing whether the obligation to register has arisen at all. This gives the DGT an independent line of inquiry into potential GloBE taxpayers, drawing on its existing data resources.
Ex officio registration
The more significant operational provision is the ex officio registration power in Article 4(7). Where a qualifying taxpayer has not applied for status addition voluntarily, the Head of the Tax Office where that taxpayer is registered may carry out the addition administratively, following an administrative examination. This removes any practical benefit a taxpayer might otherwise obtain by delaying registration.
The deadline for voluntary registration is tightly drawn. Under Article 4(2), an application for status addition must be submitted no later than nine months after the end of the first year in which the GloBE charge applies to the multinational enterprise group. Based on the regulation's publication date of August 2026, that deadline falls in September 2026 for the earliest cohort of affected groups.
Who qualifies
The threshold follows the OECD's agreed standard. A taxpayer must register as a GloBE taxpayer if it is a member of a multinational enterprise group whose consolidated revenue, as shown in the ultimate parent entity's consolidated financial statements, reached EUR 750 million or more in at least two of the four fiscal years immediately preceding the first year of GloBE imposition.
Practical implications
The ex officio mechanism substantially raises the compliance risk for groups that have not yet assessed whether they meet the EUR 750 million threshold. Where the DGT identifies a qualifying entity through its own data, it can register that entity without any application from the taxpayer, bringing the full suite of GloBE filing and payment obligations into force. Groups operating in Indonesia should confirm their revenue position against the four-year lookback period and, where the threshold is met, complete voluntary status addition before the September 2026 deadline to avoid an administratively imposed registration and any associated penalties.