Notification under the Global Minimum Tax (GloBE): Definition, Obligations, and Deadlines

The implementation of the global minimum tax or Global Anti-Base Erosion (GloBE) rules in Indonesia since 1 January 2025 has introduced new administrative consequences for Constituent Entities that form part of multinational enterprise groups. In addition to calculating and paying any Top-up Tax that may become payable, taxpayers within the scope of the GloBE rules must also comply with a series of reporting and administrative obligations designed to ensure that information concerning the group structure, reporting entities, and tax obligations can be monitored by the tax authorities.

These administrative requirements include registration as a GloBE Taxpayer, submission of the GloBE Information Return (GIR), filing of the Annual Income Tax Return for the implementation of GloBE, and submission of a Notification. Among these requirements, the Notification requires particular attention because it must generally be submitted by certain Constituent Entities located in Indonesia.

Definition of Notification under the GloBE Rules

The Notification requirements are regulated, among others, under Minister of Finance Regulation No. 136 of 2024 and Director General of Taxes Regulation No. PER-6/PJ/2026.

Under these provisions, a Notification essentially constitutes a written notice submitted by a Constituent Entity to the Director General of Taxes concerning the status and identity of certain parties within the multinational enterprise group.

At a minimum, the information included in the Notification relates to:

• the identity of the domestic taxpayer that constitutes the Ultimate Parent Entity;

• the identity of a domestic taxpayer that is not the Ultimate Parent Entity; and

• the identity of the party designated to submit the GloBE Information Return (GIR).

Accordingly, the Notification does not function merely as an additional report. It also enables the tax authority to identify which entity acts as the reporting entity and to understand the position of each entity within the multinational enterprise group's structure.

Who Must Submit a Notification?

In general, every Constituent Entity of a multinational enterprise group located in Indonesia needs to consider the Notification requirement.

However, an exception applies to a Constituent Entity that has been designated as the reporting Constituent Entity and has already submitted the GIR.

This means that the Notification obligation primarily applies to Constituent Entities that have not been designated to submit the GIR.

Where an entity already acts as the reporting entity and has fulfilled the GIR requirement, that entity is no longer required to submit a separate Notification.

This distinction is important in preventing duplication of reporting obligations within the same group.

Filing Deadline

Article 15 of PER-6/PJ/2026 regulates the deadline for submitting a Notification.

Under normal circumstances, the Notification must be submitted no later than 15 months after the end of the GloBE Fiscal Year.

For the group's first GloBE Fiscal Year, this period is extended to no later than 18 months after the end of the GloBE Fiscal Year.

The extended period for the first year provides taxpayers with transitional time to prepare group data, determine the entity acting as the reporting entity, and adapt their internal administrative systems to the relatively new GloBE reporting mechanism.

Submission through Coretax

A Notification can be prepared and submitted electronically through Coretax or through another website or application integrated with the administration system of the Directorate General of Taxes.

After the Notification has been successfully submitted, the taxpayer will receive a receipt as evidence of compliance with the requirement.

The receipt has an important function because it must be attached to the Annual Income Tax Return submitted for the implementation of GloBE.

Accordingly, evidence of the Notification submission should be retained together with other GloBE documents as part of the taxpayer's compliance documentation.

Notifications Are Subject to DGT Supervision

Compliance with the Notification requirement also falls within the supervisory scope of the Directorate General of Taxes.

PER-6/PJ/2026 authorizes the DGT to supervise GloBE Taxpayers that have registered their GloBE status, including assessing whether the Notification requirement has been fulfilled in accordance with the applicable provisions.

In addition to the substantive requirements, PER-6/PJ/2026 provides a sample format and instructions for completing the Notification in its attachments.

Taxpayers can use this format as a reference when preparing the information required before submitting the Notification through the electronic system.

Important Dates for the 2025 GloBE Fiscal Year

For taxpayers entering their first GloBE Fiscal Year in 2025, several administrative deadlines should be considered in sequence.

Registration as a GloBE Taxpayer must be completed no later than 30 September 2026.

Thereafter, where a Top-up Tax becomes payable, payment must be made in accordance with the applicable deadline, which for this period falls on 31 December 2026.

The Annual Income Tax Return for the implementation of GloBE together with the GIR or Notification must subsequently be submitted no later than 30 June 2027.

Given this sequence of deadlines, companies should not wait until the reporting deadline approaches before beginning to prepare the necessary data.

Practical Steps for GloBE Taxpayers

For multinational enterprise groups with entities in Indonesia, administrative readiness is just as important as the tax calculation itself.

Companies should first map all Constituent Entities, identify the Ultimate Parent Entity, determine the party responsible for submitting the GIR, and ensure that the other entities understand whether they are required to submit a Notification.

Coordination between the tax, finance, legal, and group headquarters functions should also begin at an early stage.

The information used for the Notification should be consistent with the GIR, GloBE Annual Income Tax Return, consolidated financial statements, and other supporting documents.

Inconsistencies between documents may result in questions during the supervisory process.

Companies should also appoint an internal person responsible for the GloBE compliance calendar.

With a structured schedule, every stage, from GloBE taxpayer registration and payment of Top-up Tax to submission of the GIR or Notification and filing of the Annual Income Tax Return, can be continuously monitored.

Closing

Notification is an important part of the global minimum tax administration mechanism in Indonesia.

The requirement assists the DGT in identifying the structure of multinational enterprise groups, their Ultimate Parent Entities, and the parties responsible for submitting the GIR.

For taxpayers, Notification compliance is not merely a formal requirement. It also forms part of their overall readiness to operate under the GloBE regime.

Constituent Entities should therefore determine at an early stage whether they act as reporting entities or as entities required to submit a Notification.

Clear allocation of roles, consistent documentation, and effective deadline management will help companies comply with their GloBE obligations in an orderly manner and reduce the risk of administrative non-compliance.