The situation
A foreign company licenses IP into Indonesia and expects reduced withholding under a tax treaty. The Indonesian payer and the foreign recipient both assume they can keep using the prior documentation routine without checking DJP's January 2026 implementation notice.
What matters first
DJP's 9 January 2026 announcement says treaty application by nonresident taxpayers uses the Formulir DGT format under PMK-112/2025. It also says older forms issued under the prior rules remain valid for their stated period. So the question is not simply 'Do we have a treaty?' The real question is whether the claim is travelling through the right current documentation path.
Why old habits can fail here
Treaty relief work often relies on repeated routines. That is exactly why procedural updates can be missed. PMK 112 and the implementation notice matter because the treaty claim is now being pushed through a clearer form-and-Coretax workflow. Assuming the old process remains fully untouched is the kind of shortcut that later creates withholding or support-file problems.
What the next step should look like
The payer and recipient should compare the current treaty file against PMK 112/2025, confirm whether an older document is still within its valid period, and align the submission route with DJP's stated Coretax pathway. In cross-border withholding work, staying current on process can be just as important as reading the treaty article correctly.
Action checklist
- 1Check whether the treaty claim should now use the PMK-112/2025 Formulir DGT format.
- 2Confirm whether any older form is still valid for its stated period.
- 3Align the filing process with the Coretax route identified by DJP.
- 4Review treaty documentation procedures before the next payment cycle, not after a withholding issue appears.
Educational content only
This scenario is for general education, not personalized tax advice. Confirm specifics with a qualified professional before acting.