Taxpayer Representation after PMK 44/2026: Who May Act as an Authorized Tax Representative?

Taxpayers do not necessarily exercise every tax right or fulfil every tax obligation personally.

For a corporate taxpayer, tax audits, objections, requests for clarification, administrative procedures, and communications with the Directorate General of Taxes may involve another person who has been specifically authorized to act on the taxpayer's behalf.

Indonesia substantially updated these rules in 2026.

Minister of Finance Regulation No. 44 of 2026 on the Requirements for Acting as an Authorized Representative in Taxation and the Procedures for Exercising Rights and Fulfilling Tax Obligations by an Authorized Representative took effect on 6 July 2026 and replaced Minister of Finance Regulation No. 229/PMK.03/2014.

One of the principal changes concerns the persons who may be appointed.

Under the new framework, a taxpayer may appoint a Tax Consultant, an Other Party, or a Family Member through a Special Power of Attorney.

Each category, however, is subject to different requirements.

Distinguishing a Statutory Representative from an Authorized Representative

Before considering who may be appointed under PMK 44/2026, it is important to distinguish a taxpayer's statutory representative from an authorized representative.

Under the General Provisions and Tax Procedures Law, a corporate taxpayer is generally represented by its management.

Specific rules also determine who represents entities in bankruptcy, dissolution, or liquidation.

This position differs from that of an authorized representative.

An individual or corporate taxpayer may appoint another person through a Special Power of Attorney to exercise specified tax rights and fulfil specified tax obligations.

A director acting as the statutory management of a limited liability company is therefore not in the same legal position as a Tax Consultant appointed under a Special Power of Attorney.

This distinction matters when a company determines who is authorized to deal with the tax authorities.

Who May Act as an Authorized Representative?

PMK 44/2026 recognizes three categories:

1. Tax Consultants;

2. Other Parties; and

3. Family Members.

This differs from the previous regime, which identified Tax Consultants and employees of the taxpayer as the principal categories.

The change does not mean that an employee can no longer assist with a company's tax affairs.

However, employee status alone is no longer a separate category conferring eligibility to act as an authorized representative.

Where an employee is not a statutory representative under the Tax Procedures Law and is intended to act under a Special Power of Attorney, the requirements applicable to an Other Party need to be considered, together with the transitional arrangements that remain available through the end of 2026.

Tax Consultants

The first category is a licensed Tax Consultant.

A Tax Consultant satisfies the competency requirement by holding a valid Tax Consultant Licence.

The professional framework was also updated in 2026 through Minister of Finance Regulation No. 55 of 2026 on Tax Consultants and Other Parties Acting as Taxpayer Representatives.

Tax Consultant Licences are classified into Levels A, B, and C.

Level A covers services to individual taxpayers, subject to specified exclusions relating to individuals resident in countries that have a Double Taxation Agreement with Indonesia.

Level B extends to individual and corporate taxpayers but excludes foreign investment companies, permanent establishments, and individuals or entities resident in treaty jurisdictions.

Level C covers all individual and corporate taxpayers.

A company should therefore not merely check whether its proposed representative is a licensed Tax Consultant.

The classification of the licence also needs to correspond with the taxpayer being represented.

This is particularly important for foreign investment companies, permanent establishments, and taxpayers with international tax characteristics.

Who Is an "Other Party"?

The second category is an Other Party.

An Other Party is an individual other than a Tax Consultant or Family Member who satisfies the applicable requirements for acting as a taxpayer's representative.

Under the framework that will apply going forward, the competency of an Other Party is evidenced through a Certificate of Registration.

PMK 55/2026 establishes the competency and registration framework.

An individual follows the applicable tax competency assessment and may receive a Certificate of Competence corresponding to the level achieved.

The Certificate of Registration is then issued in accordance with that competency classification.

A Certificate of Registration is valid for three years.

Accordingly, a person does not necessarily need to become a licensed Tax Consultant to act as an authorized tax representative.

However, a person using the Other Party route must satisfy the competency and registration requirements prescribed by the regulations.

Classification Also Matters for Other Parties

The competency framework for Other Parties is likewise divided into Levels A, B, and C.

Broadly:

Level A covers individual taxpayers, subject to specified exclusions relating to treaty-country residents.

Level B covers individual and corporate taxpayers but excludes foreign investment companies, permanent establishments, and taxpayers resident in treaty jurisdictions.

Level C covers all individual and corporate taxpayers.

Companies therefore need to review the classification stated in the representative's registration, rather than merely confirming that a registration exists.

A person holding Level B registration does not have the same scope as a Level C representative.

Family Members May Also Be Appointed

A notable feature of PMK 44/2026 is the express recognition of Family Members as potential authorized representatives.

Family includes a spouse as well as relatives by blood or marriage up to the second degree.

Unlike Tax Consultants and Other Parties, Family Members are not required to demonstrate tax competency through a Tax Consultant Licence or Certificate of Registration.

This does not mean that a family member can simply act without formal authorization.

A Special Power of Attorney remains necessary.

The family relationship must also be supported by the relevant documentation, such as a family card or the prescribed declaration where applicable.

In practice, this category is primarily relevant to individual taxpayers.

What Happened to the Employee Category?

The changed position of employees deserves particular attention from corporate taxpayers.

Under the previous regime, an employee of the taxpayer was expressly recognized as a category of authorized representative.

PMK 44/2026 no longer uses that category.

Companies should therefore not assume that a tax manager, finance manager, or tax staff member is automatically entitled to act as an authorized representative merely because that person is an employee.

The first question is whether the employee qualifies as the taxpayer's statutory representative or as a person who genuinely has authority to determine company policy or decisions under the Tax Procedures Law.

If not, and the employee is intended to act under a power of attorney, the requirements for an Other Party become relevant.

A specific transitional arrangement remains available during 2026.

Transitional Arrangement until 31 December 2026

The transitional provisions are particularly important as of September 2026.

Until 31 December 2026, an individual other than a Tax Consultant who holds a tax brevet certificate or has formal tax education of at least Diploma III level from an A-accredited higher education institution may still be appointed under the transitional mechanism.

The Special Power of Attorney must be prepared in paper form.

A copy of the relevant brevet certificate or academic qualification must be attached, and the documents are submitted directly to the relevant Tax Office or Tax Service, Dissemination and Consultation Office for administration.

A Special Power of Attorney issued under this transitional provision remains usable until the specified tax matter has been completed.

Companies that have historically relied on internally employed tax staff holding brevet certificates should therefore review the position before the transition period expires.

What Changes from 1 January 2027?

Once the transitional period ends, an Other Party will no longer be able to rely solely on a tax brevet or academic qualification as the basis for appointment.

The individual will need the relevant Certificate of Registration under the PMK 44/2026 and PMK 55/2026 framework.

Companies should therefore begin assessing their representation arrangements before the end of 2026.

Where an internal tax manager or another professional has historically represented the company, the company should determine whether that person:

• acts as a statutory representative of the taxpayer;

• will obtain a Certificate of Registration as an Other Party;

• will be replaced or supplemented by a licensed Tax Consultant; or

• requires another adjustment to the company's internal tax administration.

Planning ahead may reduce disruption once the transitional rules cease to apply.

A Special Power of Attorney Remains Essential

Meeting the eligibility requirements does not automatically authorize a Tax Consultant, Other Party, or Family Member to act for a taxpayer.

The taxpayer must still grant a Special Power of Attorney.

The document may be made electronically or in paper form.

It generally identifies matters including:

• the name and Taxpayer Identification Number of the taxpayer;

• the name and Taxpayer Identification Number of the representative;

• signatures of the relevant parties;

• the representative's status;

• the specified tax rights or obligations covered by the authority; and

• the duration of the authority.

Applicable stamp duty requirements also need to be observed.

An electronic authorization can be administered through the Taxpayer Portal, while paper documentation is submitted through the appropriate tax office under the prescribed procedure.

The Authority Must Be Specific

PMK 44/2026 uses the concept of a Special Power of Attorney.

The authorization should therefore identify the particular tax rights or obligations entrusted to the representative.

The concept relates to a specified type of tax for a particular tax year, part of a tax year, or tax period.

A Special Power of Attorney also applies to one representative.

Companies should therefore avoid relying on an overly general authorization that does not sufficiently describe the scope of tax matters covered.

In practice, identifying the tax type, relevant period, and scope of authority helps reduce uncertainty concerning what the representative may or may not do.

Can the Representative Delegate the Authority?

As a general rule, a representative may not transfer the authority received from the taxpayer to another person.

The regulations nevertheless distinguish delegation of authority from certain administrative assistance.

A representative may designate an employee or another individual to deliver or receive tax documents through the prescribed designation letter.

That individual does not replace the authorized representative in exercising the substantive authority granted under the Special Power of Attorney.

The authorized representative remains the person appointed by the taxpayer, while the designated person performs the limited document-handling function specified in the designation.

Responsibility Remains with the Taxpayer

Appointing an authorized representative does not transfer the taxpayer's underlying tax responsibility.

The representative assists in exercising rights and fulfilling obligations within the scope of the authorization.

The tax obligations themselves remain those of the taxpayer.

A company should therefore maintain internal controls over documents, tax positions, financial data, and actions undertaken by its representative.

Using an external adviser should not be treated as transferring the company's entire tax oversight function.

Obligations of the Representative

PMK 44/2026 also addresses the conduct expected of a representative.

A representative must comply with tax laws, maintain integrity and professionalism, observe applicable ethical standards, protect confidentiality, and act within the classification of the relevant licence or registration.

Representatives must also not obstruct the implementation of tax laws.

This framework means that the 2026 changes do more than expand the categories of eligible representatives.

They also place professional and non-consultant representatives within a clearer competency, conduct, and supervision framework.

When Does the Authorization End?

The authorization may terminate in several circumstances.

It ends when the period stated in the Special Power of Attorney expires.

It can also end when the taxpayer revokes the authority.

The authorization ends where the Tax Consultant Licence or Certificate of Registration is suspended or revoked.

It may also terminate where the representative is convicted of a tax crime or another criminal offence as provided under the applicable rules.

Once the authority ends, the representative can no longer exercise the rights or fulfil the obligations previously entrusted to that person.

Access granted through the Taxpayer Portal also terminates.

Replacing an Authorized Representative

A taxpayer may revoke a Special Power of Attorney.

The revocation may be administered electronically or through a paper document in accordance with the applicable process.

The revocation takes effect when the Directorate General of Taxes receives the revocation and does not apply retroactively.

Where a taxpayer wishes to appoint a new representative for the same tax matter, the previous authorization should first be revoked.

This is particularly important where a company changes its Tax Consultant during an audit, objection, or another ongoing tax procedure.

The transition between the former and new representatives should be documented clearly.

Existing Powers of Attorney

PMK 44/2026 also contains a transitional provision for authorizations that existed before the regulation took effect.

A Special Power of Attorney granted and submitted to the Directorate General of Taxes before 6 July 2026 may continue to be used for the specified tax matter in accordance with its terms.

The new regulation therefore did not automatically invalidate every previously issued authorization.

New appointments, however, should follow the framework established by PMK 44/2026.

What Should Companies Do during 2026?

Corporate taxpayers should begin by identifying the people who currently deal with the Directorate General of Taxes on the company's behalf.

The company should distinguish individuals acting as statutory representatives or management from persons acting under a Special Power of Attorney.

The status of each appointed representative should then be reviewed.

Where a Tax Consultant is used, the company should confirm that the licence remains valid and that its classification covers the relevant type of taxpayer.

Where internal employees or other professionals act as Other Parties, the company should review the transitional basis available during 2026 and determine whether registration will be required for continued representation from 2027.

The company should also review its Special Powers of Attorney, particularly the tax types, periods, scope of authority, and duration.

Finally, access granted through the Taxpayer Portal should be updated whenever a representative is appointed, replaced, or removed.

Special Considerations for Foreign Investment Companies

Foreign investment companies need to pay particular attention to the representative's classification.

Level B under the Tax Consultant and Other Party framework does not extend to foreign investment companies.

A PT PMA should therefore ensure that its representative holds a classification covering that category of taxpayer.

In general, Level C is the classification covering all individual and corporate taxpayers.

This issue matters because competency is determined not only by the representative's practical experience but also by the formal scope of the relevant licence or registration.

Conclusion

PMK 44/2026 significantly changes Indonesia's taxpayer representation framework.

Taxpayers may now appoint Tax Consultants, Other Parties, or Family Members.

The broader range of potential representatives is accompanied by clearer requirements concerning competence, classification, registration, Special Powers of Attorney, professional conduct, and supervision.

For companies, one of the most important changes is that employee status alone is no longer a separate basis for acting as an authorized representative.

Where an internal employee is not the taxpayer's statutory representative and is intended to act under a power of attorney, the requirements for an Other Party need to be considered.

The transitional period through 31 December 2026 gives companies time to adjust.

After that period, an Other Party will generally need the appropriate Certificate of Registration corresponding to the taxpayer and the tax matters being handled.

Companies should therefore use the remaining 2026 transition period to review who is authorized to deal with the tax authorities, the legal basis of that authority, the person's competency classification, and the Special Power of Attorney documentation used.