Regulation Update
Term Changes for Tax Invoice Filling

Friday, 19 August 2022

Term Changes for Tax Invoice Filling

The Director General (Dirjen) of Taxes amended the provisions regarding the tax invoice creation by issuing the Regulation of the Director General of Taxes (Perdirjen) Number PER-11/PJ/2022 which comes into force on 1 September 2022.

The regulation changes a number of provisions in the Regulation of the Director General of Taxes Number PER-03/PJ/2022 which has been in effect since 1 April 2022.

Some adjusted policies are related to the mechanism for filling out tax invoices issued for the transfer of Taxable Goods (BKP) and/or Taxable Services (JKP) that are VAT or STLG payable.

In particular, regarding filling in the address column on the tax invoice, for the submission of BKP/JKP which is provided with VAT/STLG not-collected facilities to VAT-Registered Persons (PKP) whose VAT or STLG is centralized at the Tax Office (KPP) for Large Taxpayers, Special Tax Office or Medium Tax Office.

However, the goods or services are sent to certain areas that receive VAT/STLG facilities and are not collected. If that condition occurs, then the address column is filled with the delivery address or VAT-Registered Person's address in a certain area.

These provisions are cumulative. So, if only one of the conditions is met, for example, the BKP/JKP sent does not receive facilities, but they are sent to a certain place that has facilities, then the address column is filled with the centralization of the location of the VAT/STLG.

This narrows down the previous provision, where the late provision stipulates that all transfers are made to the VAT-Registered Persons as a buyer which is centralized at the Large Tax Office. The identity in the Tax Invoice must include the name and Taxpayer Identification Number of the central VAT-Registered Persons. At the same time, the address is filled with the address of the recipient of the goods.

Specific Area Types

Specific areas in question are bonded storage (TPB), special economic zones (SEZ), or certain areas in the customs territory with other VAT or STLG not-collected facilities.

The latest regulation stipulated that if this condition occurs, the tax invoice must be filled with information on the name and Taxpayer Identification Number (NPWP) of the buyer or recipient at the location of centralization of the VAT or STLG payable.

Meanwhile, in the address column, it is filled with the location of the recipient of the BKP or JKP in TPB, SEZ or other certain areas.

For tax invoices made from 1 April to 31 August 2022, upon transfer of goods to buyers who centralize where the VAT is payable, but submitted to certain places that have facilities or who do not receive VAT or STLG not-collected facilities, the input tax can be credited.


For entrepreneurs who have already made tax invoices using the provisions of PER-03/PJ/2022, relaxation is given. So, there is no need to make changes to tax invoices.

Even though the tax invoice includes the address for the VAT/STLG centralization. In fact, taxable goods or services that are submitted, receive VAT/STLG facilities without being collected and sent to certain areas with VAT/STLG not-collected facilities.

Crediting Input Tax

Another revised provision is related to the input tax credit. In the latest regulation, specifically Article 37 paragraph (2), the government confirms that the VAT that can be credited by the buyer or recipient of services is deemed to have complied with the provisions of the law in the field of taxation.

Crediting input tax does not depend on the reporting of tax invoices in the Periodic VAT Return of the VAT-Registered Person who makes the invoice.

Apart from these matters, no other provisions regarding tax invoices have been amended. It still refers to the Director General of Taxes Number PER-03/PJ/2022.

Every VAT Registered-Person is required to make a tax invoice for each transfer of BKP, provision of JKP, export of tangible taxable goods, export of intangible taxable goods and export of taxable services.

Tax invoices can be made either at the time of submission of BKP and/or JKP, receipt of payment, receipt of term payment, at the time of export, or other times as regulated in the provisions of the legislation.

Each tax invoice made must include some information, such as the name, address and number of the taxpayer who transferred the BKP or JKP as well as the identity of the buyer of the BKP or the recipient of the JKP, such as the name, address and Tax ID number for domestic taxpayers and government agencies.

Meanwhile, for domestic tax subjects, a Single Identity Number is added. Then foreign tax subjects must also include their passport number in addition to their name and address. For foreign corporate tax subjects, it is sufficient to include the name and address.

Tax Invoice Creation

Tax invoices can also be made on a transaction basis or on a consolidated basis.
Tax invoices must be made electronically (e-invoices) through applications or channels provided by the DGT. Or it can be done offline or in a form of hardcopy under certain conditions.

Several types of e-invoice applications provided by DGT include:
1. Client Desktop e-Invoice Application
2. Web-based e-Invoice Application
3. Host-to-Host e-Invoice Application

Entrepreneurs can make e-invoices as long as they have an electronic certificate, have a verified VAT-Registered Person account, and have a Tax Invoice Serial Number (NSFP) that is provided by the DGT for each invoice.

However, NSFP will only be given to VAT Registered-Persons who already have an activation code and password, have an activated VAT Registered-Person account, and have reported Periodic VAT Return for at least the last three consecutive tax periods.

Meanwhile, a VAT Registered-Person who has just been confirmed in the month of NSFP submission and has never reported a Periodic Return can get a maximum NSFP of 75 NSFP. For the VAT Registered-Person who has issued more than 75 tax invoices in the last three tax periods, it can apply for a maximum NSFP of 120% of the total previous tax period.

After that, tax invoices can be made starting from the date of issuance of the NSFP.


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