Three Digital Tax Changes in October 2026: Marketplace Income Tax, SPP TDLN, and Coretax

By Hendrawanto, SE., Ak., CA., CLI., AseanCPA., CPA., CFI. · 4 October 2026

Entering October 2026, businesses in Indonesia face three important changes in digital tax administration:

Designated marketplaces begin collecting income tax under Article 22 (PPh Pasal 22) on the income of domestic sellers.
The government begins operating the Tax Collection System for Foreign Digital Transactions (Sistem Pemungutan Pajak atas Transaksi Digital Luar Negeri, SPP TDLN).
The mechanism for amending tax returns (SPT) in Coretax shifts from a delta scheme to a replace scheme.

None of these is merely a technical change to an application. They affect cash flow, revenue reconciliation, tax slips, the management of refunds and carried-forward overpayments, and the quality of the data companies use to meet their tax obligations. Companies that delay adjusting risk recording differences, unused tax credits, or poor decisions because tax data is out of line with commercial data.

Marketplace Income Tax (PPh Article 22) Takes Effect

The Directorate General of Taxes (DJP) announced that collection of PPh Article 22 on domestic sellers' income through marketplaces begins on 1 October 2026. The four e-commerce operators (PMSE) named in the announcement are Shopee, Blibli, Tokopedia, and Lazada. The legal basis is Minister of Finance Regulation (PMK) No. 37 of 2025.

Designated marketplaces collect PPh Article 22 at 0.5 percent of gross revenue stated on the invoice, excluding VAT (PPN) and luxury-goods sales tax (PPnBM). The tax becomes due when the marketplace receives payment. DJP emphasizes that this does not create a new type of tax; what changes is mainly the settlement mechanism, from self-payment by the seller to collection by the marketplace.

For individual sellers with revenue up to IDR 500 million in a tax year, collection may be waived provided the seller submits a statement in accordance with the regulation. This is where operational risk arises. Revenue must be assessed per taxpayer, not separately per shop or per platform. Sellers with several accounts need to consolidate gross revenue across all channels before declaring that they remain below the threshold.

PPh Article 22 that has been collected should not stop at a figure on the marketplace dashboard. For taxpayers under the general tax rate, the amount can in principle be credited against tax for the current year. For taxpayers subject to final income tax, it can form part of the final tax settlement in accordance with the regulations. Collection slips therefore need to be traced, reconciled with revenue, and mapped to the right tax account.

SPP TDLN Expands VAT Collection on Digital Transactions

The government has operated SPP TDLN since 25 September 2026, following PMK No. 49 of 2026. The system collects VAT on foreign digital transactions made by consumers in Indonesia that have not been subject to VAT through the PMSE VAT mechanism.

In the initial phase, collection involves designated issuers: BRI, Bank Mandiri, BNI, BTN, Bank Syariah Indonesia, and LinkAja. The payment system is used to identify foreign digital transactions that meet the criteria. DJP states that the mechanism is designed so that transactions already subject to VAT through PMSE VAT are not taxed twice.

For companies, the key issue is not only whether VAT is collected but whether transaction documents are sufficient to support recording and input VAT credits. Software subscriptions, cloud services, digital advertising, collaboration platforms, data, and other digital services are often paid through scattered corporate cards or accounts. Without a central register of vendors and payment instruments, companies will struggle to detect VAT, prevent duplication, and make sure invoices are tied to the correct entity.

Coretax Adopts a Replace Scheme for Tax Return Amendments

The third change relates to DJP Regulation PER-12/PJ/2026. From 1 October 2026, amendments to tax returns in Coretax use a replace scheme with a calculation rule. Put simply, the latest amended return becomes the basis for the taxpayer's rights and obligations, while the system takes into account payments, refunds, and overpayment balances that have already occurred.

This scheme replaces the delta approach, which reported only the difference. In past practice, the delta approach could produce an artificial underpayment when an overpayment position in the original return was reduced or changed, even though the earlier overpayment had not actually been refunded to the taxpayer. The replace scheme is intended to give a more complete picture of the return's latest position.

The new rule applies to amended returns filed from 1 October 2026 for tax periods or years 2025 onward that are in Coretax. Amendments for 2024 and earlier periods continue to follow the transitional mechanism in the legacy system. Companies should also note that amending an overpaid return may affect a refund process already under way, depending on whether an assessment has been issued or an audit is in progress.

Tax return amendments should therefore not be left to the application operator alone. Before filing, the tax team should reconcile the original return, all payments, withholding or collection slips, carried-forward overpayments, assessments, and refunds. Coretax's calculation needs to be matched to the tax subledger and the general ledger. Differences in overpayment balances must be explained, not simply accepted as system output.

Implications for Corporate Governance

The three changes share a pattern: tax administration is moving toward increasingly integrated use of transaction data. Marketplaces, payment systems, Coretax, and a company's internal records are becoming parts of a single information chain. Compliance quality therefore depends on consistent master data, taxpayer identity, revenue reconciliation, documentation, and control over data changes.

Boards and CFOs should not treat these changes as a matter for the tax unit alone. They involve sales, e-commerce, treasury, procurement, accounting, information technology, and internal control. A failure in one function to keep data accurate can create differences in another.

Practical Steps to Take

Inventory all marketplace accounts and link each one to the correct NPWP or NIK.
Reconcile marketplace revenue with invoices, escrow movements, settlement reports, and the general ledger.
Make sure the IDR 500 million revenue statement or exemption certificate is submitted through the marketplace mechanism where the conditions are met.
Build a register of PPh Article 22 collection slips and decide whether each is treated as a tax credit or as final tax settlement.
Compile a list of foreign digital vendors, service types, payment instruments, invoices, and VAT evidence to support the SPP TDLN review.
Update the SOP for Coretax return amendments and require tiered review before an amended return is filed.
Reconcile overpayment balances and refund status after every amendment or issued assessment.

Conclusion

October 2026 is a turning point for digital tax administration. Marketplace PPh Article 22 moves part of tax settlement onto platforms, SPP TDLN extends VAT collection on foreign digital transactions, and the replace scheme changes how tax return amendments are handled in Coretax.

The benefits of these changes will only materialize if companies put adequate data controls and reconciliations in place. The safest course is to map transactions, update SOPs, test the system's calculations, and make sure every tax document can be traced back to its source transaction.

Need support with tax reconciliation or a review of amended returns? See our Corporate Tax Advisory service.

Official References (Indonesian)

This article is general information and not tax advice for any specific situation. Application to each taxpayer depends on the facts, documents, and regulations in force. This is a translation of the Indonesian original; in case of difference, the Indonesian version prevails.