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Tax Litigation Service

Overview

Our firm offers comprehensive tax dispute and litigation resolution services in Indonesia, providing businesses and corporations with strategic and legal solutions that adhere to Indonesian tax regulations. Business Hub Asia is prepared to support clients throughout all phases, including tax audits, formal objections, appeals, and Supreme Court reviews.

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Key Features

Tax Audit Assistance

Expert consultation and representation during Directorate General of Taxes (DJP) audits to protect taxpayer rights and obligations.

Tax Objection Preparation & Submission

Drafting formal legal objections to unwarranted Tax Assessment Letters (SKPs), including legal arguments and evidence.

Appeal Assistance to the Tax Court

Advise clients on legal drafting and litigation strategies, including appeal representation for contested rulings.

Lawsuit & Judicial Review

Advanced services for legal proceedings at the high court level up to the Supreme Court, if required for dispute resolution.

Negotiation & Non-Litigation Settlement

Consider mediation or consultation with tax authorities for mutually agreeable solutions without lawsuits.

Minimum Requirements

Company legality

NIB, NPWP, deed, SK

Disputed tax assessment letter

SKPKB, SKPLB, or SKPN

Supporting Documents

Supporting documents of transactions relevant to the subject of dispute

Communication & Audit

Communication history and audit results with DGT (if any)

Process and Timeline

1

Filing an Objection to the Directorate General of Taxes (DGT)

Taxpayers (WP) who disagree with the Tax Assessment Letter (SKP) may submit a written objection to the DGT within 3 months from the date of receipt of the SKP. The DGT is obliged to provide a decision on the objection within 12 months after the objection is received. If there is no decision within the period, the objection is considered granted.

2

Appeal to the Tax Court

If the taxpayer is not satisfied with the objection decision from the DGT, the taxpayer can file an appeal to the Tax Court within 3 months after the objection decision is received. The Tax Court must decide the appeal within 12 months after the appeal request is received.

3

Filing a Lawsuit in the Tax Court

In certain cases, such as tax collection disputes or DGT decisions that cannot be appealed, taxpayers can directly file a lawsuit to the Tax Court. The lawsuit must be filed within 14 days after the implementation of the collection or 30 days after the receipt of the challenged decision.

4

Judicial Review (PK) to the Supreme Court

If taxpayers are not satisfied with the Tax Court’s decision, they can file a PK to the Supreme Court within 3 months after the decision is received. The review process at the Supreme Court can take 12 months or more, depending on the complexity of the case and the caseload at the Supreme Court.

*Overall, the process of resolving tax disputes from the objection stage to the review can take between 2 to 5 years, depending on the complexity of the case and the response of each relevant agency.

Important Consideration

  • Tax disputes must be handled promptly; delays may result in the loss of legal rights.
  • Not all disputes need to be resolved in court; a non-litigation approach can be a faster and more efficient solution.
  • The entire process is conducted based on the provisions of the Tax Law, Tax Court Law, and its derivative regulations.
  • We work with certified tax consultants and experienced tax lawyers.

Frequently Asked Questions

What is a tax dispute and when can it occur?

A tax dispute occurs when a taxpayer disagrees with the result of a tax audit or determination by the DJP, usually in the form of an SKPKB or SKPLB.

What is the first step if I disagree with the SKP?

You can file a written objection to the DJP within 3 months from the date of issuance of the SKP.

If there is a tax dispute, do I have to go directly to court?

No, that is not required. The process commences with the submission of an objection. Recourse to the Tax Court is permissible solely upon the denial or unsatisfactory resolution of said objection.

What is the difference between an objection and an appeal?

An objection is submitted to the DJP as the agency that determines the tax, while an appeal is submitted to the Tax Court as an independent institution.

How long does the tax dispute resolution process take?

Varies. The objection process usually takes up to 12 months, while appeals and lawsuits can take longer, depending on the complexity.

Can disputes be resolved without going to court?

Yes. We offer a non-litigation approach through clarification, negotiation, or mediation directly with the DJP.

Can foreign companies also use tax litigation services?

Of course. Business Hub Asia provides support to both domestic and foreign-invested companies facing taxation challenges within Indonesia.

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