The key change is that treaty relief now has to fit the PMK 112 process, not just the treaty text
DJP's implementation material on PMK 112 matters because it reframes treaty claims as an operational process. Nonresident taxpayers are directed to use the Formulir DGT format under PMK-112/2025, which means treaty entitlement now has to be presented through the current Indonesian administrative route rather than through whatever legacy document habit the parties happen to remember.
Legacy documents can remain relevant, but only within the limits DJP still recognizes
One reason the January 2026 notice is useful is that it does not pretend the old world vanished overnight. Older forms issued under the previous rules can still be used for their stated period. That makes the transition less abrupt, but it does not allow taxpayers to ignore the new structure. The safe question is always whether the older document is still within its valid life and whether the next payment should now be supported under the PMK 112 format instead.
The practical treaty file now has to be current, not just technically arguable
The best treaty workflow in Indonesia now combines three things: the signed treaty article, the right DGT form route and evidence that is current enough to support the withholding position. That is what turns a treaty claim from a legal theory into a usable administrative file. In practice, updating the support pack early is usually much cheaper than trying to untangle withholding after the domestic rate has already been applied.
Educational content only
This guide is for general education, not personalized tax advice. Tax rules change and your facts matter — confirm anything important with a qualified professional or the cited official source before taking action.