Regulation Update

DGT Adds 9 New Substitute Documents For Tax Invoice

The Directorate General of Taxes (DGT) added nine new types of documents which are equivalent to tax invoices, from the previous 16 documents to 25 documents. The position of these documents can later replace the existence of a tax invoice which is the Value Added Tax (VAT) collection slip by VAT-Registered Persons.

Some examples of new documents that can now be equated with tax invoices are receipts for credit and token payment, documents for releasing goods from bonded areas, to proof of payment of customs duties on the import consignments.

With the VAT collection slip, the VAT-Registered person who sells or delivers the taxable goods or taxable services can credit the input tax, which is the tax paid when the entrepreneur buys the goods or services.

According to DGT, the addition of documents equivalent to tax invoices aims to make it easier for taxpayers, so that there is no need to create their own tax invoices, but simply attach the documents.

The addition is regulated in the Director General of Taxes Regulation Number PER-16/PJ/2021 which changes the previous rule, namely Director General of Taxes Regulation Number PER-13/PJ/2019.  The new rules will take effect on 1 August 2021.

The following are nine additional new documents that are equivalent to tax invoices as stated in the latest regulation:

1. Proof of purchase or payment of credit purchase and token/voucher submission commission. 
2. Determination of Payment of Import Duty, Excise, and/or Tax (SPPBMCP) on consignments that includes the identity of the owner of the goods.
3. VAT collection slip on imports of goods or services carried out through Trading Through Electronic System (PMSE).
4. A Tax Assessment Notice (SKP) is commonly used to collect input tax on imports, purchases of taxable goods (BKP) or taxable services (JKP).Including those commonly used to collect input tax on the utilization of intangible goods or services from outside customs within the customs territory.
5. Customs Declaration for Special Economic Zones (PPKEK) which includes the identity of the owner of the goods.
6. Tax payment slip (SSP) for the settlement of VAT related to the submission of BKP or JKP by business actors in the SEZ to other parties who are in other places but are still located in the customs territory. With a record that when the import is carried out or when it is used, the BKP/JKP is not subject to VAT.
7. Tax payment slip for the payment of VAT related to the release of goods that are not carried out by VAT-Registered persons in the SEZ to parties in the SEZ.  With a note that when the import is carried out or when it is used, the BKP/JKP is not subject to VAT.
8. Documents for delivering BKP or JKP by VAT-Registered Persons from bonded zones.
9. Tax payment slip for the payment of VAT on the issuance of BKP belonging to a foreign tax subject from the bonded zone to another place within the customs territory.

The existence of these documents complements other documents that have been equated in the previous regulations:

1. Delivery Orders (SPPB) made or issued by the State Logistics Agency (Bulog) for the distribution of wheat flour.
2. Invoice for the transfer of telecommunications services by the telecommunications company.
3. Tickets, bill of lading (airway bill), or delivery bill, which is made/issued for the transfer of domestic air transportation services.
4. Bill of sale of port services.
5. Invoice for the transfer of BKP and/or JKP by the drinking water company.
6. Invoice (trading confirmation) for the transfer of JKP by a broker-dealer.
7. Invoice for the transfer of JKP by the bank.
8. Documents used for ordering tobacco products excise tapes (CK-1 document).
9. Export Declaration (PEB) attached with a Bill of Export Services (NPE), invoice, and bill of lading or airway bill for the export of BKP.
10. Export declaration of Intangible JKP/BKP attached with invoice
11. Import Declaration (PIB) which includes the identity of the owner of the goods, attached with tax payment slip, Customs, Excise and Tax Payment Slip (SSPCP), and/or tax collection slip by the Directorate General of Customs and Excise.
12. Import Declaration that includes the identity of the owner of the goods, attached with the tax payment slip and a letter of determination of tariffs and/or customs value
13. Letter of Determination of Tariff and/or Customs Value (SPTNP), a letter of determination of customs determination (SPP), or Letter of Re-determination of Tariff and/or Customs Value (SPKTNP)
14. Tax payment slip for VAT payment on imports of intangible BKP or JKP by attaching a bill and additional information such as the type, value, name, and address of the provider of Intangible BKP or JKP.
15. Tax payment slip for the payment of VAT on the transfer of BKP through an auctioneer accompanied by a Minutes of Auction.
16. Tax payment slip for the payment of VAT on the transfer of BKP and/or JKP from Free Zone to Other Places within Customs Territory.

However, in order to replace the function of tax invoices, these documents must meet the formal requirements stipulated. If not, they will be subject to sanctions as applicable in the Law on Taxation General Provisions and Procedures (KUP).

The formal requirements that apply to each type of document are different. However, in general, each document must contain complete information such as the identity of the taxpayer which includes the name, address, and Taxpayer Identification Number (NPWP), information related to the tax base, and the amount of VAT collected.