New Tax Representative Rules in Indonesia: PMK 44/2026 and Surat Kuasa Khusus Requirements

Indonesian companies frequently rely on external tax consultants, accountants, employees or other authorised persons to communicate with the Directorate General of Taxes, submit documents and perform specific tax-related actions.

However, appointing an accountant or granting a general corporate power of attorney does not automatically mean that the appointed person is legally qualified to act as a tax representative.

Indonesia introduced new rules governing tax representatives through Ministry of Finance Regulation No. 44 of 2026, commonly referred to as PMK 44/2026.

The regulation was issued on 22 June 2026 and entered into force on 6 July 2026. It replaced the previous framework under PMK No. 229/PMK.03/2014.

PMK 44/2026 regulates:

- who may be appointed as a tax representative;
- the professional competence required;
- registration in the Directorate General of Taxes system;
- the use of a Surat Kuasa Khusus;
- the scope and duration of tax authority;
- electronic representation through the taxpayer portal;
- revocation and replacement of a representative;
- transitional treatment for existing representatives and powers of attorney.

The new framework is particularly relevant to PT PMA companies and other corporate taxpayers that delegate tax matters to external consultants, accounting firms, employees or local administrative personnel.

A company should not assume that an existing relationship with an accountant is sufficient.

The practical compliance question is whether the person acting for the company falls within an authorised category, holds the required licence or registration, is properly recorded in the tax administration system and has received a valid special power of attorney covering the relevant tax matter.

The company itself continues to remain responsible for its tax rights and obligations even when those matters have been delegated to a representative.

This means that an invalid appointment, incomplete power of attorney or unauthorised action may create direct compliance risk for the taxpayer.

Foreign directors and shareholders should therefore review not only who performs the company’s tax work, but also who is formally authorised to represent the company before the Indonesian tax authority.

PMK 44/2026 defines the categories of persons who may be appointed to exercise specific tax rights or fulfil specific tax obligations on behalf of a taxpayer.

A taxpayer may appoint:

- a licensed tax consultant;
- another registered person classified as Pihak Lain;
- a qualifying family member.

These categories should not be treated as interchangeable.

Each category is subject to different qualification, registration and documentary requirements.

For companies, including PT PMA companies, the most relevant categories are normally a licensed tax consultant or a registered Pihak Lain.

The family exception is primarily relevant to individual taxpayers because a company does not have family relationships in the same legal sense as a natural person.

### Licensed Tax Consultant

A tax consultant may act as a tax representative where the consultant holds a valid Izin Konsultan Pajak.

The licence confirms that the person has satisfied the applicable professional requirements for providing tax services.

However, holding a professional title or working for an accounting or consulting firm is not enough by itself.

The company should verify:

- the identity of the individual representative;
- the validity of the Izin Konsultan Pajak;
- whether the licence is suspended or revoked;
- whether the person is registered in the DJP administrative system;
- whether the Surat Kuasa Khusus covers the relevant tax matter.

The appointment is made in favour of the individual representative, not merely the consulting firm, accounting firm or employer named in the commercial engagement.

This distinction matters where a company signs a service agreement with a firm but a specific individual actually represents the taxpayer before DJP.

### Registered Pihak Lain

A taxpayer may also appoint a person classified as Pihak Lain.

Pihak Lain means a person who is not a licensed tax consultant and is not appointed under the family exception, but who holds a valid Surat Keterangan Terdaftar.

The Surat Keterangan Terdaftar confirms that the person is registered and permitted to act as a tax representative under the applicable rules.

A company should therefore not assume that an employee, accountant, finance manager, external bookkeeper or administrative consultant automatically qualifies as Pihak Lain.

The person must hold the required registration status.

The company should check:

- whether a Surat Keterangan Terdaftar has been issued;
- whether it remains valid;
- whether it has been suspended or revoked;
- whether the representative has been registered in the DJP system;
- whether the appointment is supported by a compliant Surat Kuasa Khusus.

Employment by the taxpayer does not automatically replace these requirements.

An internal employee may have extensive knowledge of the company’s accounts and tax records but may still lack authority to formally represent the company for a particular tax matter.

### Family Exception

PMK 44/2026 also allows a taxpayer to appoint a qualifying family member.

Family includes:

- a husband or wife;
- a blood relative up to the second degree;
- a relative by marriage up to the second degree.

A family representative is exempt from the general professional competence requirement that applies to tax consultants and Pihak Lain.

However, this exception should not be interpreted as a general option for corporate taxpayers.

A PT PMA cannot normally rely on the personal family relationship of a director or shareholder to appoint that relative as the company’s tax representative.

The family category is connected to the taxpayer whose rights and obligations are being represented.

It is therefore principally relevant where the taxpayer is an individual.

### Valid Professional Status Is Essential

A tax consultant cannot act as a representative if the consultant’s licence has been suspended or revoked.

Similarly, a Pihak Lain cannot act where the Surat Keterangan Terdaftar has been suspended or revoked.

A company should not rely only on copies of certificates received when the relationship began.

The validity of the representative’s status should be checked when the power of attorney is issued and reviewed periodically during the engagement.

This is particularly important where the representative handles:

- tax audits;
- objection procedures;
- document submissions;
- clarification requests;
- tax account administration;
- specific filings;
- communication with DJP;
- access through the taxpayer portal.

### Registration in the DJP Administrative System

A licensed tax consultant or Pihak Lain must also be registered in the administrative system of the Directorate General of Taxes.

Registration is completed using the representative’s valid professional licence or registration certificate.

The relevant documents may be submitted electronically through the taxpayer portal or directly through the appropriate tax office.

A valid professional document and DJP system registration should therefore be treated as separate compliance checks.

The company should verify both.

### The Commercial Service Provider and the Legal Representative May Be Different

A company may engage an accounting firm, tax advisory firm or corporate service provider under a commercial agreement.

However, the contracting firm itself may not be the individual named in the Surat Kuasa Khusus.

The company should identify:

- which firm provides the service;
- which individual performs the work;
- which individual is formally registered;
- which individual is named as the tax representative;
- whether the authority covers the required tax action.

This distinction reduces the risk that the company believes it has appointed an authorised representative when it has only entered into a general service arrangement.

The central compliance question is not whether a person works as an accountant or tax specialist.

The central question is whether that person belongs to an authorised category, holds the required professional status, is registered with DJP and has received a valid special power of attorney.

A company employee does not automatically have the right to represent a PT PMA before the Directorate General of Taxes.

Employment, job title and access to the company’s accounting records are not the same as formal authority to exercise the taxpayer’s rights or fulfil its tax obligations.

An employee may prepare calculations, collect documents, coordinate with advisers or perform internal administrative work.

However, where the employee formally acts as a tax representative under a Surat Kuasa Khusus, the employee must satisfy the applicable requirements under PMK 44/2026.

For a corporate taxpayer, the company should first distinguish between:

- a director or another person acting as the company’s lawful representative;
- an employee performing internal tax administration;
- an employee appointed as a formal tax representative;
- an external tax consultant;
- another registered person acting as Pihak Lain;
- a person authorised only to deliver or collect documents.

These roles are legally and operationally different.

### Acting Through a Corporate Position

A director may perform certain actions for the company because the director represents the company under its corporate structure and applicable company documents.

This authority arises from the person’s corporate position rather than from appointment as an external tax representative.

The company should nevertheless verify:

- whether the director remains validly appointed;
- whether the director’s authority is reflected in the company’s AHU records;
- whether internal approval is required;
- whether the relevant tax system access has been granted;
- whether the particular procedure requires a Surat Kuasa Khusus.

A corporate position should not be confused with professional tax competence.

A director may have authority to represent the company but may still rely on a qualified tax professional for technical tax matters.

### Internal Administrative Support

Employees in accounting, finance, legal, administration or tax departments may support the company’s compliance work without becoming formal tax representatives.

Their internal responsibilities may include:

- preparing tax data;
- compiling invoices and supporting documents;
- maintaining accounting records;
- coordinating with a tax consultant;
- monitoring filing deadlines;
- preparing internal reports;
- arranging signatures;
- uploading documents under authorised procedures.

The company should document these responsibilities through job descriptions, internal policies and access controls.

Internal support does not by itself authorise the employee to make formal representations, sign submissions, respond to an audit or exercise the company’s tax rights before DJP.

### Employee Appointed as Pihak Lain

An employee may potentially act as a tax representative if the person qualifies as Pihak Lain.

In that case, the employee must hold a valid Surat Keterangan Terdaftar and must be registered in the DJP administrative system.

The company should verify:

- the employee’s identity and NPWP;
- the validity of the Surat Keterangan Terdaftar;
- the classification and permitted scope of the registration;
- the employee’s registration in the DJP system;
- the absence of suspension or revocation;
- the specific authority granted in the Surat Kuasa Khusus.

The employment relationship does not replace any of these requirements.

A finance manager, accountant or tax officer who does not hold the required status should not be described in the Surat Kuasa Khusus as an authorised Pihak Lain merely because that person works for the company.

### Employee Holding a Tax Consultant Licence

An employee who holds a valid Izin Konsultan Pajak may potentially act under the tax consultant category, subject to the applicable professional and registration rules.

The company should not rely solely on the employee’s statement that the licence exists.

It should review:

- the licence number;
- validity period;
- licence classification;
- DJP registration;
- any suspension or revocation;
- whether the proposed tax activity falls within the permitted professional scope.

The company should also consider whether the employee’s role creates any internal conflict between professional representation, employment duties and corporate approval requirements.

### Brevet or Tax Diploma Holders

A brevet certificate or tax diploma does not automatically create permanent authority to represent a company under the new framework.

PMK 44/2026 includes transitional treatment for certain persons who previously relied on a tax brevet or qualifying tax diploma.

That transitional route is temporary and subject to specific documentary and procedural requirements.

A PT PMA relying on an employee with only a brevet or diploma should therefore verify:

- whether the person qualifies for the transitional arrangement;
- whether the required paper Surat Kuasa Khusus has been prepared;
- whether the supporting certificate or diploma has been attached;
- whether the appointment has been submitted through the relevant tax office;
- whether the authority remains valid after 31 December 2026.

The company should not assume that the employee may continue acting indefinitely after the transition period.

### Delivering and Receiving Documents

A person who is not the formal tax representative may still be authorised to deliver or receive certain documents in accordance with the applicable procedure.

This limited administrative function is different from exercising the taxpayer’s tax rights or fulfilling tax obligations as a representative.

A document courier, employee or assistant should not:

- provide substantive tax explanations beyond the granted authority;
- sign documents reserved for the taxpayer or representative;
- respond to an audit as if formally appointed;
- access electronic tax functions without proper approval;
- transfer or expand the representative’s authority.

The company should clearly document whether the person is acting as:

- a formal representative;
- an internal employee;
- a document delivery person;
- an authorised system user;
- a supporting member of the tax team.

### Why the Distinction Matters

An unclear appointment may create several risks.

The tax office may reject a document or refuse to recognise the person’s authority.

The company may also lose time during an audit, objection, clarification request or other time-sensitive process.

There may be additional risk if an employee:

- submits information outside the authorised scope;
- accesses the taxpayer portal without proper approval;
- continues acting after employment ends;
- retains access after the power of attorney is revoked;
- communicates with DJP without internal authorisation;
- relies on an expired licence or registration.

The company should therefore maintain a written tax authority matrix identifying:

- the company’s lawful corporate representative;
- the appointed tax representative;
- the scope of the Surat Kuasa Khusus;
- internal employees with administrative responsibilities;
- persons with taxpayer portal access;
- document delivery or collection authority;
- expiry and revocation dates.

The correct question is not simply whether the person is an employee.

The correct question is whether the person has the legal status, registration, specific authority and system access required for the particular tax action.

A Surat Kuasa Khusus is not a general corporate power of attorney.

It is a special tax power of attorney granted by a taxpayer to one authorised representative for specific tax rights or obligations.

The document should clearly identify who grants the authority, who receives it, what tax matters are covered and how long the authority remains valid.

A vague or overly general power of attorney may not provide sufficient authority for the intended tax action.

Under PMK 44/2026, a Surat Kuasa Khusus should include at least:

- the name, NPWP and signature of the taxpayer granting the authority;
- the name, NPWP and signature of the appointed representative;
- the representative’s status as a tax consultant, Pihak Lain or qualifying family member;
- the specific tax rights or obligations being delegated;
- the validity period of the power of attorney;
- payment of the applicable stamp duty.

For corporate taxpayers, the document should also identify the individual signing on behalf of the company and that person’s position.

The company should verify that the signatory has valid authority to represent the taxpayer.

### Identify the Taxpayer Correctly

The Surat Kuasa Khusus should use the company’s official legal name and NPWP exactly as recorded in the tax administration system.

For a corporate taxpayer, the document should also identify the representative of the taxpayer who signs the appointment.

This may include:

- the director’s name;
- the director’s NPWP;
- the director’s position;
- the basis on which the director acts for the company.

The information should remain consistent with the company’s current corporate records.

An outdated director name, incorrect company name or inconsistent NPWP may create administrative problems.

### Identify the Individual Representative

The representative must be identified as an individual.

The company should not name only an accounting firm, law firm, tax advisory firm or corporate service provider.

The Surat Kuasa Khusus should state:

- the representative’s full name;
- the representative’s NPWP;
- the relevant licence or registration number;
- the representative’s legal category.

For a licensed tax consultant, the relevant document is the `Izin Konsultan Pajak`.

For Pihak Lain, the relevant document is the `Surat Keterangan Terdaftar`.

Where the family category applies, the family relationship should be stated and supported in accordance with the applicable requirements.

### Define the Specific Tax Matter

The authority should describe the particular tax rights or obligations delegated to the representative.

This may include a specific process relating to:

- a tax audit;
- an objection;
- a clarification request;
- a refund procedure;
- submission of particular documents;
- a specific tax type;
- a specific tax period;
- another defined administrative action.

The document should not rely only on broad language such as:

“to handle all tax matters.”

The more precise approach is to identify:

- the relevant procedure;
- the type of tax;
- the tax period or year;
- the specific acts the representative may perform.

The representative may act only within the authority expressly granted.

### One Power of Attorney, One Representative

A single Surat Kuasa Khusus may appoint only one representative.

The company should not place several consultants, employees or firm personnel in one document as joint tax representatives.

Where different individuals are appointed for different matters, each appointment should be structured clearly.

The company should also check whether the authority overlaps with an existing appointment.

If a new representative is appointed for the same tax rights or obligations, the previous power of attorney may need to be revoked first.

### State the Validity Period

The Surat Kuasa Khusus should include a clear start date and end date.

The validity period should be appropriate for the tax procedure concerned.

A company should avoid:

- leaving the period blank;
- using an indefinite period without considering the specific tax matter;
- relying on a power of attorney after the underlying procedure has ended;
- allowing the appointment to continue after the representative’s engagement or employment ends.

The company should maintain a central record of all active tax powers of attorney and their expiry dates.

### Include the Required Stamp Duty

The power of attorney must satisfy the applicable stamp duty requirements.

The company should verify that:

- the required meterai has been applied;
- the document is signed correctly;
- the signing format is consistent with the applicable procedural rules.

A properly drafted document may still be administratively defective if the stamp duty requirement has not been completed.

### Paper and Electronic Forms

A Surat Kuasa Khusus may be created electronically or in paper form.

An electronic power of attorney is submitted through the `Portal Wajib Pajak`.

A paper power of attorney is submitted directly through the relevant tax office and must be recorded in the DJP administrative system.

The company should confirm not only that the document has been signed, but also that it has been properly submitted and registered.

A signed document kept only in the company’s internal records may not be sufficient for formal representation before DJP.

### Electronic Tax Actions Require Portal Access

Where the representative will exercise tax rights or fulfil tax obligations electronically, the taxpayer must grant the representative access through the `Portal Wajib Pajak`.

The power of attorney and portal access are connected but should not be treated as identical.

The company should verify:

- that the electronic authority has been granted;
- which functions are accessible;
- whether access matches the scope of the Surat Kuasa Khusus;
- when access expires;
- whether access is removed after revocation or termination.

A representative should not receive unrestricted access if the appointment covers only a limited tax matter.

### Use the Prescribed Example Format

PMK 44/2026 includes an example format for the Surat Kuasa Khusus.

The example covers:

- taxpayer identification;
- corporate representative details;
- representative category;
- licence or registration information;
- specific tax rights and obligations;
- tax type and period;
- duration;
- electronic access;
- signatures and stamp duty.

The safest drafting approach is to use the prescribed structure and adapt it carefully to the actual appointment.

A company should avoid copying an old template without checking whether it reflects the new requirements.

### Supporting Documents

Depending on the representative’s category and the form of appointment, supporting documents may also be required.

These may include:

- evidence of the tax consultant licence;
- evidence of the Surat Keterangan Terdaftar;
- evidence of family relationship;
- a statement required for the family category;
- transitional brevet or tax diploma documents;
- evidence of the corporate signatory’s authority.

The company should prepare the supporting documents at the same time as the power of attorney.

### Practical Validation Check

Before relying on a Surat Kuasa Khusus, the company should confirm:

- the taxpayer details are accurate;
- the corporate signatory is authorised;
- the individual representative is correctly identified;
- the licence or registration is valid;
- the scope of authority is specific;
- the tax type and period are stated;
- the validity period is clear;
- the stamp duty requirement is satisfied;
- the document has been submitted through the correct channel;
- electronic access has been granted only where necessary;
- no conflicting prior appointment remains active.

A valid Surat Kuasa Khusus is therefore more than a signed letter.

It is a coordinated legal and administrative appointment that must match the representative’s status, the company’s records, the intended tax action and the DJP system.

PMK 44/2026 recognises that tax representation may be created and administered electronically.

This is particularly important for companies using the Directorate General of Taxes’ electronic systems, including Coretax and the Portal Wajib Pajak.

An electronic appointment is not simply a scanned copy of a signed power of attorney.

The company should distinguish between:

- creating or submitting the Surat Kuasa Khusus electronically;
- registering a paper power of attorney in the DJP system;
- granting the representative access to electronic tax functions;
- controlling the scope and duration of that access.

These steps are related, but they are not identical.

### Electronic Surat Kuasa Khusus

A Surat Kuasa Khusus may be prepared in electronic form and submitted through the Portal Wajib Pajak.

Under PMK 44/2026, an electronic Surat Kuasa Khusus is treated as submitted to the Directorate General of Taxes when the electronic document has been completed in the system.

The company should therefore verify that the process has been finalised rather than merely drafted or saved.

A practical review should confirm:

- the taxpayer account used for the appointment;
- the identity of the representative;
- the representative’s NPWP;
- the relevant licence or registration;
- the specific tax authority granted;
- the tax type and period;
- the start and end dates;
- successful completion of the electronic submission.

The company should retain evidence of the completed electronic appointment.

### Paper Powers of Attorney

A Surat Kuasa Khusus may also be created in paper form.

In that case, it must be submitted directly through the relevant tax service office or tax service, counselling and consultation office.

The paper appointment must then be administered in the DJP system.

A company should not assume that a signed paper document kept by the accountant or tax consultant has automatically become effective for electronic tax administration.

The company should confirm:

- where the document was submitted;
- when it was received;
- whether it has been recorded in the DJP system;
- which authority has been recognised;
- whether additional portal access is required.

### Portal Access Is a Separate Operational Requirement

Where the appointed representative will exercise tax rights or fulfil tax obligations electronically, the taxpayer must approve access through the Portal Wajib Pajak.

This means that a valid Surat Kuasa Khusus alone may not be sufficient for electronic action.

The taxpayer should also grant the corresponding system access.

The company should treat portal access as a controlled digital permission rather than unrestricted access to the entire tax account.

The access should match the authority granted in the power of attorney.

For example, where the representative has been appointed only for a specific audit, objection, tax period or document submission, the company should avoid granting broader access than is reasonably required.

### Coretax Access Should Match the Legal Authority

In practice, many companies refer to their electronic tax environment as Coretax.

Whatever interface is used, the legal and operational principle remains the same:

The representative’s electronic access should correspond to the specific tax rights or obligations delegated by the taxpayer.

The company should compare:

- the wording of the Surat Kuasa Khusus;
- the functions enabled in the taxpayer portal;
- the tax periods covered;
- the identity of the user receiving access;
- the duration of the appointment.

A mismatch may arise where:

- the power of attorney is limited but the system access is broad;
- the document has expired but the electronic access remains active;
- the representative has changed but the former user still has access;
- the person accessing the system is not the individual named in the power of attorney;
- several staff members use one representative’s credentials;
- the commercial service agreement has ended but the portal authority has not been reviewed.

### Do Not Share the Taxpayer’s Credentials

A company should not solve an access problem by giving the representative the director’s or taxpayer’s personal login details.

Sharing credentials weakens accountability and may make it difficult to identify who performed a particular action.

The safer structure is to use the official delegation and access mechanism provided in the DJP system.

This helps maintain:

- individual user identification;
- controlled permissions;
- an auditable record;
- clearer responsibility;
- easier access termination.

The company should also avoid allowing several employees or external advisers to use the same login.

### One Named Representative

A Surat Kuasa Khusus applies to one named representative.

The same principle should guide electronic access.

The individual who receives system access should be the person formally appointed and properly registered.

Where a tax advisory or accounting firm provides the service, the company should confirm which individual within that firm:

- holds the relevant licence or registration;
- is named in the power of attorney;
- receives portal access;
- is responsible for electronic actions.

Firm-level engagement does not eliminate the need to identify the individual representative.

### Internal Staff and Supporting Personnel

An appointed representative may work with employees or supporting personnel.

However, support staff should not automatically receive the representative’s full electronic authority.

The company should distinguish between:

- the formal tax representative;
- internal employees preparing data;
- personnel uploading or delivering documents under an authorised process;
- persons receiving limited system access;
- users who only review internal records.

Each role should have an appropriate level of access.

The representative’s authority should not be transferred informally through shared credentials or internal instructions.

### Access Duration and Expiry

Electronic access should be reviewed against the validity period of the Surat Kuasa Khusus.

The company should maintain records showing:

- when access was granted;
- which functions were enabled;
- the related power of attorney;
- the expiry date;
- the responsible internal approver;
- the date access was removed.

Under PMK 44/2026, access granted to the representative ends when the underlying authority ends.

The company should nevertheless verify the system status in practice rather than relying only on the document expiry date.

### Revocation and Access Removal

Where the taxpayer revokes a Surat Kuasa Khusus, the revocation becomes effective when it is received by DJP and does not operate retroactively.

The company should coordinate the legal revocation with the operational removal of electronic access.

A complete revocation process should include:

1. preparation of the revocation document;
2. submission through the correct electronic or paper channel;
3. confirmation of receipt by DJP;
4. removal of Portal Wajib Pajak or Coretax access;
5. review of internal passwords and permissions;
6. collection or transfer of company tax records;
7. appointment of a replacement representative where required.

If a new representative will handle the same tax matter, the previous appointment should be revoked before the new appointment is made.

### Access Review After Personnel Changes

A tax access review should be triggered when:

- a director changes;
- an employee resigns;
- the company changes accounting firms;
- a tax consultant is replaced;
- a licence or registration is suspended;
- a power of attorney expires;
- a tax audit or objection is completed;
- the company restructures its tax function.

Foreign directors should not assume that access is automatically removed when a service contract or employment relationship ends.

The company should check the actual status in the tax system.

### Practical Electronic Access Checklist

Before allowing a representative to act electronically, the company should confirm:

- the Surat Kuasa Khusus has been completed and submitted;
- the representative is correctly registered with DJP;
- the representative’s licence or SKT is valid;
- the portal user matches the named representative;
- the authorised tax matter is clearly defined;
- access is limited to the necessary functions;
- the validity period is recorded;
- credentials are not shared;
- access removal procedures are documented;
- former representatives no longer retain active authority.

Electronic tax representation should therefore be treated as both a legal appointment and an information-access control process.

The company must verify not only whether the representative is authorised on paper, but also whether the right person has the correct level of electronic access for the correct period.

PMK 44/2026 limits each Surat Kuasa Khusus to one named representative and to the specific tax rights or obligations stated in the document.

This rule is central to the new representation framework.

A company should not treat a tax power of attorney as a broad appointment allowing an advisory firm, accounting team or group of employees to act without individual identification and defined limits.

The document should answer two questions clearly:

- who is authorised to act;
- what exactly that person is authorised to do.

### One Surat Kuasa Khusus, One Individual

A single Surat Kuasa Khusus may appoint only one representative.

The appointed person should be identified individually through the required personal and professional information.

The company should not use one power of attorney to appoint:

- several employees;
- an entire accounting department;
- multiple consultants from the same firm;
- a company without naming the individual representative;
- a primary representative together with informal substitutes.

Where a tax advisory firm is engaged, the commercial service agreement may be signed with the firm.

However, the Surat Kuasa Khusus should identify the individual who holds the required professional status and will formally act for the taxpayer.

The company should therefore maintain a clear distinction between:

- the service provider engaged under a commercial contract;
- the individual appointed as tax representative;
- supporting personnel assisting that representative.

### Different Representatives for Different Tax Matters

A company may require assistance from different specialists for different tax procedures.

For example, one representative may handle a tax audit while another adviser supports a separate objection, refund or administrative matter.

In that case, the company should prepare separate appointments that clearly define:

- the individual representative;
- the relevant tax procedure;
- the tax type;
- the tax period or year;
- the permitted actions;
- the validity period.

The appointments should not overlap in a way that creates uncertainty about who has authority over the same tax matter.

The company should also verify whether any existing appointment must be revoked before granting the same authority to a new representative.

### Authority Must Be Specific

The appointed representative may exercise only the tax rights or fulfil only the tax obligations expressly delegated in the Surat Kuasa Khusus.

The document should not rely on general wording that gives the representative unlimited control over all company tax matters.

The scope may need to identify:

- the relevant type of tax;
- the tax period, part of a tax year or tax year;
- the administrative procedure;
- the documents that may be submitted or received;
- the meetings or communications the representative may attend;
- the statements or responses the representative may make;
- the electronic functions the representative may access.

A company should draft the authority according to the actual procedure.

For example, authority to submit documents during an audit should not automatically be treated as authority to file an objection, accept a settlement, amend unrelated returns or access all historical tax records.

### Tax Type and Period Matter

PMK 44/2026 connects specific tax representation to defined tax rights or obligations.

The Surat Kuasa Khusus should therefore identify the relevant tax type and period wherever applicable.

This may include:

- one tax type for one tax year;
- one tax type for part of a tax year;
- one or more tax periods;
- several tax types where they form part of one connected procedure.

The description should be precise enough for the taxpayer, representative and DJP to understand the boundaries of the appointment.

A vague appointment can create uncertainty during time-sensitive tax procedures.

### No Substitution of the Representative

The appointed representative may not transfer the authority received from the taxpayer to another person.

This means that the representative cannot issue a new power of attorney allowing another consultant, employee or colleague to exercise the delegated tax rights in their place.

The authority remains personal to the individual named in the Surat Kuasa Khusus.

This rule is particularly important where a company appoints a representative working within a larger tax or accounting firm.

The firm should not assume that another member of staff may replace the named representative informally.

If the representative changes, the company should review whether it needs to:

- revoke the existing power of attorney;
- appoint the replacement formally;
- update DJP system records;
- change Portal Wajib Pajak access;
- revise the internal authority matrix.

### Limited Appointment for Document Delivery or Collection

The prohibition on transferring representative authority does not prevent the appointed representative from asking an employee or another person to deliver or receive specific tax documents.

This is a limited administrative appointment.

It does not make the appointed person a tax representative.

The representative should issue a separate written appointment identifying:

- the person delivering or receiving the documents;
- the relevant Surat Kuasa Khusus;
- the specific documents involved;
- the related tax procedure.

The appointed person should present that written appointment each time the relevant documents are delivered or collected.

This limited role does not authorise the person to:

- provide substantive tax explanations;
- make decisions for the taxpayer;
- sign documents as the tax representative;
- amend the scope of the original authority;
- access electronic tax functions without separate approval;
- delegate the task further.

### Supporting Staff Do Not Become Representatives

A tax representative may receive assistance from colleagues, employees or administrative staff.

They may help prepare documents, organise records, communicate internally or support the representative’s work.

However, supporting participation should not be confused with formal authority.

The company should know which individuals are:

- formally appointed representatives;
- authorised document couriers;
- internal company staff;
- external support personnel;
- electronic system users.

Each role should be documented separately.

### Avoid Shared Credentials and Informal Substitution

A company should not allow another person to act under the named representative’s electronic credentials.

This can create uncertainty over:

- who submitted information;
- who made a statement;
- whether the action was authorised;
- whether the person had valid professional status;
- whether the activity remained within the power of attorney.

The individual named in the Surat Kuasa Khusus should remain identifiable throughout the process.

Where another person needs formal authority, the company should use the proper appointment procedure instead of informal credential sharing.

### Scope Review Before Important Tax Actions

Before a representative performs an important tax action, the company should check whether the Surat Kuasa Khusus expressly covers it.

This is especially relevant before:

- responding to a tax audit;
- filing an objection;
- submitting a refund request;
- attending a formal meeting;
- delivering a substantive written explanation;
- receiving an official tax decision;
- accessing electronic records;
- signing or submitting procedural documents.

The company should not assume that authority for one stage automatically covers every later stage.

A new or amended appointment may be required where the procedure changes.

### Practical Authority Matrix

A PT PMA should maintain an internal record showing:

- the name of each appointed representative;
- the representative’s legal category;
- the licence or registration number;
- the relevant Surat Kuasa Khusus;
- the covered tax type and period;
- the authorised tax actions;
- the start and expiry dates;
- electronic access granted;
- supporting personnel authorised to deliver or receive documents;
- revocation or replacement status.

This record helps directors and internal finance teams understand who may act for the company and where the limits of that authority begin and end.

The principle is straightforward:

A tax power of attorney should not create general or transferable control over the company’s tax affairs.

It should create a specific, personal and verifiable authority for one representative to perform defined tax actions.

PMK 44/2026 introduces a temporary transition for certain persons who are not licensed tax consultants but previously relied on a tax brevet certificate or formal tax education to act as tax representatives.

This transition is limited in time and should not be treated as permanent authority.

A person other than a licensed tax consultant may continue to be appointed as a tax representative until 31 December 2026 where that person holds:

- a tax brevet certificate; or
- a formal tax diploma of at least Diploma III level issued by a public or private higher education institution with A accreditation status.

The transitional provision is particularly relevant to companies that currently rely on:

- internal tax employees;
- finance managers;
- external accountants;
- bookkeeping providers;
- administrative consultants;
- other individuals who have a brevet or tax diploma but do not yet hold a valid Surat Keterangan Terdaftar.

A company should not assume that the existence of a brevet certificate or diploma is sufficient by itself.

The transitional appointment is subject to a specific documentary and submission process.

### The Appointment Deadline

The person may be appointed under this transitional route only until 31 December 2026.

This is a deadline for making the qualifying appointment.

It does not mean that every power of attorney issued under the transition automatically ends on 31 December 2026.

Where the appointment has been made in accordance with the transitional provisions, the relevant Surat Kuasa Khusus may continue until the specific tax rights or obligations covered by that document have been completed.

The company should therefore distinguish between:

- the deadline for appointing the transitional representative;
- the duration of the tax procedure covered by the power of attorney;
- the validity of the representative’s future status after the transition period.

### Paper Surat Kuasa Khusus Is Required

An appointment under the transitional provision must use a paper Surat Kuasa Khusus.

The company should not rely only on an electronic appointment through the taxpayer portal for this transitional route.

The paper power of attorney should clearly identify:

- the taxpayer;
- the corporate signatory;
- the individual representative;
- the representative’s NPWP;
- the specific tax rights or obligations;
- the relevant tax type and period;
- the duration of the appointment;
- the basis for relying on the transitional provision.

The document should also satisfy the general requirements applicable to a Surat Kuasa Khusus.

### Supporting Certificate or Diploma

The paper power of attorney must be accompanied by a copy of:

- the brevet certificate; or
- the qualifying formal tax diploma.

Where the appointment relies on a diploma, the company should verify that:

- the qualification is specifically in taxation;
- the education level is at least Diploma III;
- the diploma was issued by a public or private higher education institution;
- the institution held A accreditation status as required by the regulation.

A general accounting, finance, business or legal diploma should not automatically be treated as a qualifying tax diploma.

### Direct Submission Through the Tax Office

The transitional Surat Kuasa Khusus must be submitted directly through:

- the relevant Kantor Pelayanan Pajak; or
- the relevant Kantor Pelayanan, Penyuluhan, dan Konsultasi Perpajakan.

The appointment is then recorded in the administrative system of the Directorate General of Taxes.

The company should retain evidence showing:

- the date of submission;
- the tax office receiving the document;
- the supporting certificate or diploma submitted;
- confirmation that the appointment was recorded;
- the specific tax matter covered.

A document signed internally but never submitted through the required channel should not be treated as a completed transitional appointment.

### The Transition Does Not Create Permanent Status

The transitional rule does not convert a brevet holder or tax diploma holder automatically into a permanently registered Pihak Lain.

After 31 December 2026, companies should expect formal tax representation to depend on the status required under the new framework.

This may involve:

- appointment of a licensed tax consultant;
- appointment of a person holding a valid Surat Keterangan Terdaftar;
- the taxpayer acting through its lawful corporate representative;
- another structure permitted under the applicable tax rules.

A person relying only on a brevet or diploma should not assume that the same basis will remain available for new appointments after the transition ends.

### Review Existing Internal Tax Personnel

PT PMA companies should identify whether any current tax representative is acting only on the basis of:

- brevet A;
- brevet B;
- brevet C;
- another tax course certificate;
- a tax diploma;
- an internal job title;
- prior practice under the former regulation.

The company should then verify whether the person:

- qualifies for the transition;
- has been appointed using a paper Surat Kuasa Khusus;
- has submitted the required supporting documents;
- has been recorded in the DJP system;
- is handling a defined tax matter;
- requires a permanent status solution after 2026.

This review should be completed before the transition period ends.

### Existing Service Agreements Should Also Be Reviewed

A company may have a service agreement with an accountant or consulting provider stating that the provider will represent the company before DJP.

That commercial clause does not replace the regulatory requirements for tax representation.

The company should compare:

- the service agreement;
- the individual named in the Surat Kuasa Khusus;
- the person’s brevet or diploma;
- the submission record;
- the authority recorded in the DJP system;
- the planned representation structure after 31 December 2026.

Where the commercial provider cannot continue under the new framework, the service arrangement may need to be amended.

### Do Not Wait Until a Tax Audit or Deadline

The transition issue may become visible only when the company needs the representative to perform an urgent action.

This may happen during:

- a tax audit;
- an objection period;
- a document request;
- a refund process;
- a formal clarification;
- a deadline for submitting evidence.

If the representative’s status is challenged at that stage, the company may have limited time to appoint a replacement.

The safer approach is to review the representative’s status before an urgent tax procedure arises.

### Practical Transition Checklist

A company relying on a brevet or tax diploma holder should confirm:

- the person is not being presented as a licensed tax consultant unless a valid licence exists;
- the certificate or diploma qualifies under the transitional provision;
- the appointment is made no later than 31 December 2026;
- a paper Surat Kuasa Khusus is used;
- the supporting certificate or diploma is attached;
- the document is submitted through the appropriate tax office;
- the appointment is recorded in the DJP system;
- the tax matter and validity period are specific;
- the company has a plan for representation after the transition period.

The transitional provision gives companies time to adapt.

It should not be interpreted as permission to continue indefinitely with an informal or unregistered representation arrangement.

PMK 44/2026 does not automatically invalidate every Surat Kuasa Khusus issued under the previous regulatory framework.

The transitional provisions distinguish between powers of attorney that had already been issued and submitted to the Directorate General of Taxes before the new regulation entered into force and new appointments made after that date.

This distinction is important for companies that were already involved in a tax audit, objection, refund procedure, clarification process or another tax matter when PMK 44/2026 became effective.

### The Relevant Date Is 6 July 2026

PMK 44/2026 entered into force on 6 July 2026.

A Surat Kuasa Khusus that was issued and submitted to DJP before that date may continue to be used for the specific tax rights or obligations stated in the document.

The company should therefore verify two separate facts:

- when the power of attorney was signed;
- when it was actually submitted to DJP.

A document signed before 6 July 2026 but never submitted may not receive the same transitional treatment as a document that had already been formally delivered and recorded.

The company should retain evidence of submission.

This may include:

- a DJP receipt;
- tax office acknowledgement;
- electronic submission confirmation;
- correspondence confirming acceptance;
- another administrative record showing that the appointment was submitted before the effective date.

### Existing Authority Remains Limited to Its Original Scope

A qualifying pre-existing Surat Kuasa Khusus continues only within the authority already granted.

It should not be treated as a general authorisation for new or unrelated tax matters.

The company should review:

- the tax type;
- the relevant tax period or year;
- the specific tax procedure;
- the representative named;
- the permitted actions;
- the stated duration.

For example, a power of attorney issued for a particular tax audit should not automatically be relied upon for a later objection, refund claim or separate tax year.

A new Surat Kuasa Khusus may be required when the company begins a different tax procedure.

### Existing Powers Do Not Automatically Expand Under the New Regulation

The transitional rule preserves qualifying existing authority.

It does not expand that authority.

A representative cannot rely on an old power of attorney to exercise rights that were never stated in the document.

The company should avoid assuming that an earlier appointment covers:

- all tax types;
- all future periods;
- every interaction with DJP;
- unrestricted electronic access;
- authority to appoint another representative;
- unrelated proceedings that began after 6 July 2026.

The wording of the existing document remains decisive.

### Review the Representative’s Current Status

Even where the old power of attorney remains usable for its original purpose, the company should review the representative’s present status.

This includes checking:

- whether the representative is still engaged by the company;
- whether the individual remains available;
- whether any professional licence or registration has been suspended or revoked;
- whether the tax procedure is still active;
- whether electronic access remains appropriate;
- whether the company intends to replace the representative.

A transitional rule should not be used to continue an arrangement that no longer reflects the company’s actual tax representation structure.

### New Tax Matters Should Follow PMK 44/2026

Where a new appointment is made on or after 6 July 2026, the company should prepare the Surat Kuasa Khusus under the new framework.

The appointment should reflect:

- the authorised category of representative;
- the required licence or Surat Keterangan Terdaftar;
- DJP system registration;
- the specific tax rights or obligations;
- the applicable tax type and period;
- the validity period;
- electronic access where required;
- the new prescribed format and supporting documents.

The company should not continue using an old template simply because it was accepted under the previous regulation.

### Amendments May Require a New Appointment

A company should review whether a new power of attorney is needed when:

- the representative changes;
- the tax procedure changes;
- a different tax period becomes relevant;
- additional tax types are added;
- the previous document expires;
- the original scope is insufficient;
- the company wants to grant electronic access not previously covered.

Trying to amend an old appointment informally may create uncertainty over the actual authority recognised by DJP.

A properly prepared new appointment is generally clearer where the material terms of the representation have changed.

### Review Old Powers of Attorney Systematically

A PT PMA should create a register of every tax power of attorney issued before 6 July 2026.

For each document, the company should record:

- date of signature;
- date of submission to DJP;
- name of the representative;
- representative category;
- tax matter covered;
- tax type and period;
- validity period;
- current status of the procedure;
- electronic access granted;
- whether revocation or replacement is required.

The company should not review only the most recent document.

An old representative may still appear in the company’s records or retain electronic access even though the commercial engagement has ended.

### Do Not Replace a Valid Existing Appointment Without a Reason

A qualifying old power of attorney does not necessarily need to be replaced immediately merely because PMK 44/2026 has entered into force.

Where the document:

- was properly issued and submitted before 6 July 2026;
- clearly identifies the representative;
- covers a specific ongoing tax matter;
- remains within its stated duration;
- continues to reflect the company’s intention;

the company may be able to continue relying on it for that defined matter.

However, the company should document the review and confirm why the existing appointment remains appropriate.

### When Replacement Is Advisable

Replacement may be advisable where:

- there is no evidence that the old document was submitted;
- the scope is vague;
- the representative is no longer engaged;
- the tax matter has changed;
- the power of attorney has expired;
- professional status is uncertain;
- access rights are broader than the legal authority;
- the company is appointing a new representative;
- the old document conflicts with the company’s current records.

The company should coordinate any replacement with the revocation requirements under PMK 44/2026.

### Practical Review Checklist

For every Surat Kuasa Khusus issued before 6 July 2026, the company should ask:

- Was it signed before the effective date?
- Was it submitted to DJP before the effective date?
- Is there evidence of submission?
- Which specific tax matter does it cover?
- Is that matter still ongoing?
- Is the named representative still acting?
- Does the representative still have valid status?
- Is the stated validity period still open?
- Does portal access match the original authority?
- Is revocation or replacement now required?

The correct conclusion is not that all old powers of attorney became invalid on 6 July 2026.

The correct conclusion is that each existing appointment should be reviewed against its submission date, specific scope, duration and current operational use.

A company should have a clear procedure for ending a tax representative’s authority and appointing a replacement.

This is particularly important where the company changes its tax consultant, terminates an employee, restructures its accounting function or discovers that the existing representative no longer holds the required professional status.

Under PMK 44/2026, a Surat Kuasa Khusus may be revoked by the taxpayer.

The revocation may be submitted electronically or in paper form, depending on how the appointment is administered.

The revocation becomes effective when it is received by the Directorate General of Taxes.

It does not apply retroactively.

This means that actions properly performed before the revocation takes effect remain part of the existing representation history.

### Revoke Before Appointing a Replacement for the Same Matter

Where the company intends to appoint a new representative for the same tax rights or obligations, the existing power of attorney should be revoked first.

The company should not allow two representatives to appear simultaneously authorised for the same tax matter unless the appointments are clearly separated by scope.

A replacement process should normally follow this sequence:

1. identify the existing Surat Kuasa Khusus;
2. confirm the tax matter and period it covers;
3. prepare the revocation;
4. submit the revocation through the correct channel;
5. confirm receipt by DJP;
6. remove the former representative’s electronic access;
7. prepare the new Surat Kuasa Khusus;
8. register the replacement representative;
9. grant only the necessary portal access;
10. record the change internally.

This sequence reduces the risk of overlapping authority.

### Review the Existing Appointment First

Before revoking a representative, the company should review:

- the name and NPWP of the representative;
- the original appointment date;
- the tax type and period;
- the tax procedure covered;
- the stated validity period;
- any electronic access granted;
- whether the matter remains active;
- whether documents or deadlines are pending.

The company should avoid revoking authority in the middle of a time-sensitive procedure without ensuring continuity.

For example, a tax audit response, objection deadline or document submission may already be in progress.

The replacement should be coordinated so that the company does not lose access to records, procedural history or communication with DJP.

### Electronic Revocation

Where the power of attorney is administered electronically, the taxpayer may revoke it through the relevant taxpayer portal process.

The company should retain evidence showing:

- the date of revocation;
- the representative affected;
- the tax matter concerned;
- successful submission;
- confirmation that the authority has ended.

The company should also verify the status in the system after submission.

A revocation should not be treated as complete merely because an internal instruction has been sent to the consultant or employee.

### Paper Revocation

Where a paper appointment is used, the revocation should also be submitted through the applicable tax office procedure.

The company should retain:

- a signed copy of the revocation;
- proof of delivery;
- acknowledgement from the receiving office;
- the effective date;
- evidence that the DJP record has been updated.

The revocation should identify the original Surat Kuasa Khusus clearly enough to avoid uncertainty.

### Remove Portal and Coretax Access

Legal revocation and electronic access removal should be handled together.

A former representative should not continue to have active access to the taxpayer portal, Coretax functions or company tax records after the authority has ended.

The company should review:

- Portal Wajib Pajak access;
- Coretax permissions;
- internal accounting systems;
- cloud storage;
- shared email accounts;
- document repositories;
- passwords and authentication devices;
- access to tax correspondence.

The company should not assume that electronic permissions disappear automatically when a service agreement or employment relationship ends.

### Recover Company Records

The outgoing representative may hold important tax information, including:

- filed returns;
- working papers;
- audit correspondence;
- objection documents;
- tax payment records;
- invoices;
- reconciliations;
- system exports;
- passwords or access instructions;
- copies of prior powers of attorney.

The company should require an organised handover.

The handover should identify:

- documents returned;
- documents transferred electronically;
- unresolved tax matters;
- pending deadlines;
- communications with DJP;
- advice already provided;
- actions still required.

A replacement representative should not be expected to reconstruct the entire tax history without support.

### Verify the New Representative Before Appointment

Before appointing the replacement, the company should confirm:

- the individual’s legal category;
- valid Izin Konsultan Pajak or Surat Keterangan Terdaftar;
- DJP system registration;
- NPWP;
- professional status;
- scope of permitted representation;
- availability for the relevant procedure.

The new Surat Kuasa Khusus should then define:

- the tax type;
- the tax period or year;
- the procedure;
- the permitted actions;
- the validity period;
- electronic access;
- any supporting documents.

The company should not simply copy the former power of attorney and change the name.

The replacement document should reflect the actual new appointment.

### Update Commercial Agreements

A company may also need to amend or terminate the underlying service agreement with the former provider.

The service agreement and Surat Kuasa Khusus are separate documents.

Ending one does not always automatically end the other.

The company should therefore review:

- termination of the service agreement;
- outstanding fees;
- confidentiality obligations;
- document ownership;
- handover duties;
- data deletion;
- liability for prior work;
- continued cooperation during transition.

The new provider’s commercial agreement should also be coordinated with the new tax authority.

### Employee Departure

Where the representative is an employee, resignation or termination of employment should trigger an immediate authority review.

The company should confirm:

- whether the employee was formally named in a Surat Kuasa Khusus;
- whether the employee held portal access;
- whether any tax procedure remains open;
- whether a replacement is required;
- whether documents and credentials have been returned.

Employment termination alone should not be treated as sufficient evidence that the tax authority has been revoked in the DJP system.

### Change of Tax Consultant

When changing tax consultants, companies often focus only on the commercial engagement.

The legal representation should be reviewed separately.

The company should identify:

- which individual from the old firm was formally appointed;
- whether more than one power of attorney exists;
- which tax matters remain active;
- whether the old firm still has access;
- whether a formal revocation has been submitted;
- whether the new firm has nominated a properly qualified individual.

This is especially important where the outgoing and incoming firms overlap during a transition period.

### Maintain a Revocation Register

A PT PMA should maintain a record of all revoked tax powers of attorney.

The register should include:

- original representative;
- original appointment date;
- covered tax matter;
- revocation date;
- date received by DJP;
- electronic access removal date;
- replacement representative;
- record handover status;
- pending matters transferred.

This record supports internal control and future due diligence.

### Practical Replacement Checklist

Before treating a representative change as complete, the company should confirm:

- the old authority has been identified;
- the revocation has been submitted;
- DJP receipt has been confirmed;
- portal and Coretax access has been removed;
- company records have been returned;
- pending tax matters have been handed over;
- the new representative’s status has been verified;
- a new Surat Kuasa Khusus has been completed;
- the replacement has been registered;
- internal records have been updated.

Replacing a tax representative is not only a change of service provider.

It is a coordinated legal, administrative and information-access process that should leave no uncertainty about who may act for the company.

A PT PMA should treat tax representation as part of its wider corporate compliance framework.

The company should not review only whether an accountant or consultant has been engaged.

It should verify whether the person acting before the Directorate General of Taxes has the correct legal status, a valid appointment, appropriate system access and authority limited to the relevant tax matter.

A structured review should cover the representative, the power of attorney, electronic access, internal approvals and the company’s records.

### 1. Identify Who Currently Acts for the Company

The company should begin by identifying every person who currently performs tax-related functions.

This may include:

- directors;
- internal finance employees;
- internal tax employees;
- external accountants;
- tax consultants;
- corporate service providers;
- administrative staff;
- document couriers;
- former representatives who may still retain access.

The company should distinguish between people who only prepare information and those who formally communicate or act before DJP.

A person who calculates taxes or prepares documents is not necessarily the company’s authorised tax representative.

### 2. Confirm the Representative’s Legal Category

Each formal representative should fall within an authorised category.

For a corporate taxpayer, the relevant person will normally be:

- a licensed tax consultant;
- a registered Pihak Lain;
- a lawful corporate representative acting through the company’s corporate structure;
- a person relying on the temporary 2026 transition where all conditions are satisfied.

The company should not rely only on a job title such as:

- accountant;
- finance manager;
- tax specialist;
- consultant;
- compliance officer.

The legal category and supporting status should be verified separately.

### 3. Verify the Licence or Registration

Where the representative is a tax consultant, the company should review the valid Izin Konsultan Pajak.

Where the representative acts as Pihak Lain, the company should review the valid Surat Keterangan Terdaftar.

The review should confirm:

- the individual’s full name;
- licence or registration number;
- validity;
- applicable professional scope;
- absence of suspension or revocation;
- consistency with DJP records.

A copy collected several years earlier should not be treated as sufficient without checking the current status.

### 4. Check DJP System Registration

A valid professional document and registration in the DJP administrative system are separate compliance elements.

The company should confirm that the appointed individual is properly registered and recognised in the relevant tax system.

It should also verify that the person named in the system is the same person named in the Surat Kuasa Khusus.

The company should investigate any mismatch involving:

- name;
- NPWP;
- licence number;
- representative category;
- active status.

### 5. Review Every Active Surat Kuasa Khusus

The company should maintain copies of all active tax powers of attorney.

Each document should be checked for:

- correct company name;
- correct NPWP;
- authorised corporate signatory;
- name and NPWP of the representative;
- representative category;
- licence or registration information;
- specific tax rights or obligations;
- tax type;
- tax period or year;
- start and end dates;
- signatures;
- stamp duty;
- submission status.

The company should avoid relying on documents that contain broad or indefinite wording.

### 6. Confirm That the Scope Matches the Actual Tax Matter

The authority granted should correspond to the procedure being handled.

For example, the company should verify separately whether the representative may:

- respond during a tax audit;
- submit supporting documents;
- attend meetings;
- file an objection;
- receive official decisions;
- handle a refund procedure;
- access electronic tax records;
- act for a particular tax period.

Authority granted for one process should not automatically be assumed to cover another.

### 7. Review Powers of Attorney Issued Before 6 July 2026

Existing documents should be classified according to:

- signature date;
- submission date;
- evidence of receipt by DJP;
- original scope;
- validity period;
- current use.

A qualifying power of attorney submitted before 6 July 2026 may remain usable for the specific authority already granted.

However, the company should not treat it as authority for new or unrelated tax matters.

### 8. Identify Reliance on the 2026 Transition

The company should identify any person acting only on the basis of:

- a brevet certificate;
- a qualifying tax diploma;
- prior practice under the former regulation.

For each such person, the company should confirm:

- qualification under the transition;
- appointment no later than 31 December 2026;
- use of a paper Surat Kuasa Khusus;
- attachment of supporting documents;
- direct submission through the relevant tax office;
- recording in the DJP system;
- a future representation plan.

The transition should not become a substitute for permanent compliance planning.

### 9. Check Portal Wajib Pajak and Coretax Access

The company should compare electronic access against the legal authority granted.

It should identify:

- who currently has access;
- which functions are enabled;
- which tax periods are visible;
- when the access was granted;
- when it expires;
- which power of attorney supports it.

The company should remove access that is:

- no longer required;
- broader than the representative’s authority;
- linked to a former employee;
- linked to a former consultant;
- supported by an expired or revoked appointment.

### 10. Prohibit Shared Credentials

Directors, employees and external advisers should not share personal or taxpayer login credentials.

The company should use the formal delegation and access mechanisms available within the DJP system.

Shared credentials can weaken:

- audit trails;
- individual accountability;
- access control;
- evidence of authorisation;
- incident investigation.

Each user should act through an identifiable and properly authorised account.

### 11. Review Internal Corporate Authority

The person signing the Surat Kuasa Khusus on behalf of the PT PMA should have valid authority to represent the company.

The company should verify:

- current director appointment;
- AHU records;
- articles of association;
- internal approval requirements;
- board or shareholder approval where relevant;
- consistency with tax system data.

A valid representative appointment can still be questioned if the person granting the authority lacked corporate authority.

### 12. Separate the Service Agreement From the Power of Attorney

The commercial engagement with an accounting or tax firm should be reviewed separately from the Surat Kuasa Khusus.

The service agreement should regulate matters such as:

- scope of professional services;
- fees;
- reporting;
- confidentiality;
- document ownership;
- liability;
- termination;
- handover.

The Surat Kuasa Khusus should regulate the specific tax authority granted to the named individual.

The company should not assume that signing one document automatically completes the other.

### 13. Check for Overlapping Appointments

The company should identify whether more than one representative appears to hold authority over the same tax matter.

Possible causes include:

- an old power of attorney that was never revoked;
- a new consultant appointed before the former appointment ended;
- separate documents using overlapping language;
- portal access retained by former personnel;
- appointments managed by different internal departments.

Overlapping authority can create uncertainty and inconsistent communication with DJP.

### 14. Maintain a Tax Authority Register

The PT PMA should maintain a central register showing:

- representative name;
- representative category;
- licence or SKT number;
- relevant service provider;
- tax matter;
- tax type and period;
- appointment date;
- submission date;
- expiry date;
- portal access;
- revocation date;
- handover status.

The register should be reviewed periodically and after any material personnel or service-provider change.

### 15. Establish Review Triggers

The company should perform an immediate tax representation review when:

- a tax consultant changes;
- an accountant is replaced;
- an employee resigns;
- a director changes;
- a licence or registration expires;
- a tax audit begins;
- an objection is filed;
- a new power of attorney is required;
- the company restructures;
- due diligence is conducted;
- an investor or bank requests compliance information.

These events can reveal weaknesses in appointments that were previously treated as routine.

### 16. Keep Evidence of Compliance

The company should retain:

- signed powers of attorney;
- electronic submission confirmations;
- tax office receipts;
- licence and registration copies;
- evidence of DJP registration;
- portal access records;
- revocation documents;
- handover records;
- internal approvals;
- representative correspondence.

This documentation may become important during an audit, dispute, due diligence review or change of adviser.

### Practical PT PMA Review Table

A company can organise the review using the following structure:

| Compliance item | What to verify |
|---|---|
| Representative identity | Full name, NPWP and authorised category |
| Professional status | Valid tax consultant licence or SKT |
| DJP registration | Active and consistent system record |
| Surat Kuasa Khusus | Specific scope, period, signatures and stamp duty |
| Corporate signatory | Valid authority to act for the PT PMA |
| Electronic access | Matches the legal authority and duration |
| Existing appointments | No expired or overlapping powers |
| Transitional status | Valid only where 2026 conditions are met |
| Revocation | Properly submitted and confirmed |
| Records | Complete evidence retained by the company |

The purpose of the checklist is not only to confirm that a document exists.

It is to confirm that the full representation structure is legally valid, operationally controlled and consistent with the company’s actual tax compliance process.

Foreign-owned companies often delegate tax administration to local employees, accountants or external consultants because foreign directors may not manage day-to-day tax procedures personally.

That operational arrangement is common, but it can create compliance risk where the company does not distinguish between tax preparation, internal administration, electronic access and formal representation before the Directorate General of Taxes.

PMK 44/2026 places greater emphasis on the identity, professional status, registration and specific authority of the individual acting for the taxpayer.

The regulation applies to representatives appointed by both individual and corporate taxpayers and has been effective since 6 July 2026. :contentReference[oaicite:0]{index=0}

### Assuming the Accountant Is Automatically Authorised

One of the most common risks is assuming that the person preparing the company’s tax returns is automatically entitled to represent the company before DJP.

An accountant may be responsible for:

- bookkeeping;
- tax calculations;
- return preparation;
- reconciliation;
- document collection;
- payment monitoring.

Those responsibilities do not automatically establish formal tax representation authority.

The company should separately verify whether the individual:

- is acting through a valid corporate position;
- holds a valid tax consultant licence;
- holds a valid Surat Keterangan Terdaftar as Pihak Lain;
- qualifies under the temporary 2026 transition;
- is named in a compliant Surat Kuasa Khusus.

A commercial service agreement with an accounting firm is not a substitute for this verification.

### Appointing the Firm Instead of the Individual

A PT PMA may sign an engagement letter with a tax advisory, accounting or corporate service firm.

However, formal tax authority should identify the individual representative who satisfies the regulatory requirements.

Risk arises where:

- the company knows only the firm name;
- several staff members communicate with DJP interchangeably;
- the individual named in the power of attorney is no longer working on the account;
- another employee of the firm uses the representative’s credentials;
- the company has not checked the individual’s licence or registration.

The company should record both:

- the service provider engaged commercially;
- the individual appointed legally.

### Using a General Corporate Power of Attorney

Another risk is relying on a general corporate power of attorney that authorises broad administrative or legal actions but does not satisfy the requirements of a Surat Kuasa Khusus.

A general power of attorney may be useful for internal corporate matters or other transactions.

It should not automatically be treated as sufficient for formal tax representation.

The tax appointment should identify:

- one representative;
- the specific tax right or obligation;
- the relevant tax type and period;
- the duration;
- the representative’s legal status;
- the required supporting documents.

### Using an Outdated Template

A company may continue using a tax power of attorney template prepared under the previous regulation.

That template may omit important information required under the new framework.

Possible weaknesses include:

- no representative category;
- no licence or registration details;
- no defined validity period;
- no specific tax type;
- no relevant tax period;
- no electronic access provision;
- several representatives named in one document;
- overly broad authority.

New appointments made after 6 July 2026 should be reviewed against PMK 44/2026 rather than copied from an old document without modification.

### Relying on a Brevet After the Transition Ends

A company may rely on an employee or external accountant who holds a brevet certificate but does not hold a tax consultant licence or Surat Keterangan Terdaftar.

PMK 44/2026 provides a temporary transition for qualifying brevet and tax diploma holders, but the route is subject to specific conditions and a deadline of 31 December 2026.

Risk arises where the company assumes that:

- a brevet creates permanent representation rights;
- an electronic appointment is sufficient under the transition;
- no supporting document is required;
- the person may continue receiving new appointments after the transition;
- the existing arrangement does not require review.

Companies relying on the transition should prepare a permanent representation solution before the deadline becomes operationally urgent.

### Failing to Check Professional Status

A representative may have held a valid licence or registration when first engaged.

The company may continue relying on old copies without checking whether the status remains active.

This creates risk where:

- the licence has expired;
- the registration has been suspended;
- the status has been revoked;
- the DJP system record is incomplete;
- the identity or NPWP does not match.

Professional status should be reviewed when the representative is appointed and periodically during the engagement.

### Granting Authority That Is Too Broad

Some companies attempt to avoid repeated documentation by granting authority over all present and future tax matters.

This can expose the company to unnecessary legal and operational risk.

A broad appointment may allow the representative to act beyond the matter originally intended by the directors.

It can also make it difficult to determine:

- which tax periods are covered;
- which procedures were approved;
- when the authority should end;
- which electronic permissions are appropriate;
- whether a later action was authorised.

The Surat Kuasa Khusus should be specific enough to make the boundaries of authority clear.

### Authority That Is Too Narrow or Incomplete

The opposite problem can also occur.

A power of attorney may be so narrow that it does not cover a necessary procedural step.

For example, it may authorise document submission but not:

- attendance at a meeting;
- receipt of an official decision;
- response to a clarification request;
- filing an objection;
- use of a particular electronic function.

The company should review the complete anticipated procedure before finalising the authority.

### Overlapping Representatives

A former consultant may still hold an active power of attorney when a new consultant is appointed.

Different internal departments may also issue separate appointments without checking the company’s central records.

Overlapping authority may lead to:

- inconsistent communication with DJP;
- conflicting submissions;
- duplicate document requests;
- uncertainty over electronic access;
- disputes over responsibility;
- confidentiality concerns.

For the same tax rights or obligations, the previous appointment should be reviewed and revoked before the replacement is appointed.

### Former Employees Retaining Access

An employee may leave the company while still retaining:

- Portal Wajib Pajak access;
- Coretax permissions;
- accounting system access;
- tax correspondence;
- company documents;
- shared passwords.

Employment termination alone may not complete the formal revocation process.

The company should coordinate:

- revocation of the Surat Kuasa Khusus;
- removal of tax-system access;
- return of records;
- transfer of pending matters;
- internal credential changes.

### Sharing Credentials

Foreign directors may provide personal or taxpayer credentials to accountants or employees because it appears to be the easiest way to complete electronic procedures.

This weakens the company’s control environment.

Shared credentials make it difficult to establish:

- who performed the action;
- whether the person was authorised;
- whether the activity remained within the approved scope;
- whether access continued after the relationship ended.

The company should use official delegation mechanisms rather than informal credential sharing.

### Mismatch Between the Document and Electronic Access

A representative may receive narrow authority in the Surat Kuasa Khusus but broad electronic access in Coretax or the Portal Wajib Pajak.

The reverse may also occur: the representative may be properly appointed but unable to complete the procedure because the necessary electronic access was never granted.

The company should compare:

- the written authority;
- the system permissions;
- the tax period;
- the permitted functions;
- the validity period;
- the named user.

The legal appointment and electronic access should correspond.

### No Evidence of Submission

A company may possess a signed power of attorney but have no evidence that it was submitted to or recorded by DJP.

This is especially important for:

- paper appointments;
- powers of attorney issued before 6 July 2026;
- appointments relying on the 2026 transition;
- documents managed entirely by an external provider.

The company should retain submission receipts, electronic confirmations or tax-office acknowledgements.

### Director Authority Is Outdated

The individual signing the Surat Kuasa Khusus for the PT PMA may no longer be a valid director or may not have authority under the company’s current corporate records.

Possible causes include:

- an unrecorded director change;
- outdated AHU data;
- expired corporate appointment;
- internal approval requirements not followed;
- inconsistency between corporate and tax-system records.

The company should verify the corporate signatory before issuing the appointment.

### No Central Authority Register

Where powers of attorney are managed informally, the company may not know:

- how many appointments exist;
- who currently holds authority;
- which tax matters are covered;
- which documents have expired;
- who has electronic access;
- which former representatives require revocation.

A central register is a simple but important control.

### Insufficient Handover When Changing Advisers

Changing the tax consultant without an organised handover can disrupt ongoing procedures.

The outgoing provider may hold:

- audit files;
- objection drafts;
- DJP correspondence;
- tax calculations;
- payment records;
- original documents;
- system access information.

The company should complete the handover before the previous representative loses access or cooperation becomes difficult.

### Treating Delegation as a Transfer of Responsibility

PMK 44/2026 does not remove the taxpayer’s responsibility merely because a representative has been appointed.

The company remains responsible for its tax rights and obligations.

Foreign directors should therefore maintain oversight of:

- submissions made;
- positions taken;
- information disclosed;
- deadlines;
- tax-system access;
- unresolved procedures.

The representative performs defined actions for the taxpayer, but the company should not treat the appointment as a transfer of ultimate compliance responsibility.

### Practical Risk-Control Measures

A foreign-owned company can reduce these risks by:

- identifying every person involved in tax administration;
- distinguishing support roles from formal representation;
- verifying the individual representative’s status;
- reviewing every active Surat Kuasa Khusus;
- matching written authority with electronic access;
- prohibiting shared credentials;
- maintaining an authority register;
- reviewing appointments after personnel changes;
- documenting revocation and handover;
- monitoring transitional appointments before 31 December 2026.

The principal risk is not simply that a power of attorney may contain a drafting error.

The broader risk is that the company’s legal authority, professional representation, electronic access and actual tax operations may not correspond to one another.

A taxpayer may appoint a licensed tax consultant, another person holding the required registration as Pihak Lain, or a qualifying family member.

For a corporate taxpayer such as a PT PMA, the most relevant categories are normally a licensed tax consultant or a properly registered Pihak Lain.

The company should verify the individual representative’s professional status, DJP registration and specific authority before relying on the appointment.

Employment by the company does not automatically give an employee formal authority to represent a PT PMA before the Directorate General of Taxes.

An employee may assist with accounting, document preparation and internal tax administration.

However, where the employee is formally appointed under a Surat Kuasa Khusus, the employee must fall within an authorised category and satisfy the applicable registration and competence requirements.

A job title such as accountant, finance manager or tax officer is not sufficient by itself.

A tax consultant should hold a valid Izin Konsultan Pajak.

A representative acting as Pihak Lain should hold a valid Surat Keterangan Terdaftar and be registered in the DJP administrative system.

The company should also check that the professional status has not been suspended or revoked and that the person named in the Surat Kuasa Khusus is the same individual recognised in the DJP system.

A Surat Kuasa Khusus should identify the taxpayer, the individual representative, the representative’s legal category and the specific tax rights or obligations being delegated.

It should also state the relevant tax type and period where applicable, define the validity period, include the required signatures and satisfy the applicable stamp duty requirements.

For a corporate taxpayer, the individual signing on behalf of the company should have valid authority to represent the company.

No. One Surat Kuasa Khusus appoints one named representative.

Where a company uses different representatives for different tax matters, each appointment should be documented separately and should define the relevant procedure, tax type, tax period and permitted actions.

The company should avoid overlapping appointments for the same tax rights or obligations.

The appointed representative cannot transfer the substantive tax authority received from the taxpayer to another representative.

The representative may issue a limited written appointment allowing an employee or another person to deliver or receive specific tax documents.

That limited administrative appointment does not authorise the person to exercise the taxpayer’s rights, make substantive representations or act as the formal tax representative.

A Surat Kuasa Khusus issued and submitted to DJP before 6 July 2026 may continue to apply to the specific tax rights or obligations stated in the document.

The transitional treatment does not expand the original authority to new tax matters, additional periods or unrelated procedures.

The company should retain evidence showing when the document was submitted and should review its scope, duration and current operational use.

PMK 44/2026 provides a temporary route for certain persons holding a tax brevet certificate or a qualifying tax diploma.

A qualifying appointment must be made no later than 31 December 2026 and must follow the special transitional procedure, including the use of a paper Surat Kuasa Khusus and submission of supporting documents through the relevant tax office.

The transition does not automatically give the person permanent authority to accept new appointments after the transition period.

No. The legal appointment and electronic system access are connected but separate compliance steps.

Where the representative will perform tax actions electronically, the taxpayer should grant the corresponding access through the Portal Wajib Pajak.

The system permissions should match the specific scope and duration of the Surat Kuasa Khusus.

Where a new representative will handle the same tax rights or obligations, the company should revoke the previous Surat Kuasa Khusus before completing the replacement appointment.

The company should confirm that DJP has received the revocation, remove the former representative’s electronic access, complete the document handover and verify the new representative’s professional status.

A new Surat Kuasa Khusus should then be prepared for the replacement representative with a clearly defined scope and validity period.

No. The taxpayer remains responsible for its tax rights and obligations even after appointing a representative.

A PT PMA should therefore maintain oversight of filings, information submitted to DJP, electronic access, procedural deadlines and the scope of authority granted to the representative.

Delegation of specific tax actions does not transfer the company’s ultimate compliance responsibility.

Tax representation should be reviewed together with the company’s broader corporate, contractual and governance structure.

The following articles provide additional guidance on agreements, shareholder relationships and business risk management in Indonesia:

• Joint Venture in Indonesia: Legal Structure, Key Agreements and Investor Risks
• Shareholder Agreement Indonesia: What Foreign Investors and Business Partners Should Include
• Business Agreement Review in Indonesia: What Businesses Must Check Before Signing
• Commercial Agreements for Foreign Investors in Bali