Indonesia Implements New Tax Regulations for Citizens Abroad

Enhanced Tax Assessment Framework

The Indonesian Directorate General of Taxes (DJP) has introduced Regulation PER-23/PJ/2025, effective since December 9, 2025, to clarify and strengthen tax status determination for Indonesian citizens working or residing abroad ¹

. This new regulation updates the criteria for being considered a foreign tax subject, moving beyond the simple 183-day presence test to a more comprehensive assessment ²

Source 2

https://finance.detik.com/berita-ekonomi-bisnis/d-8272059/lama-kerja-di-luar-negeri-wni-belum-tentu-lolos-dari-pajak-ri

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Key Features of the New Regulation

1. Tiered Assessment Mechanism: The regulation introduces a multi-criteria evaluation to determine tax residency status. This includes ³

   Source 3

   https://nasional.kontan.co.id/news/ditjen-pajak-perjelas-status-pajak-diaspora-indonesia
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   • Physical presence abroad for more than 183 days within a 12-month period
   • Permanent residence established outside Indonesia
   • Center of vital interests indicating stronger economic and social ties abroad
   • Family presence and organizational memberships in foreign countries

2. Economic Ties Assessment: The regulation considers various factors such as source of income, family residence, and membership in foreign organizations to determine an individual's tax status ²

   Source 2

   https://finance.detik.com/berita-ekonomi-bisnis/d-8272059/lama-kerja-di-luar-negeri-wni-belum-tentu-lolos-dari-pajak-ri
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3. Stricter Compliance: The new rule aims to prevent tax avoidance by Indonesian citizens living abroad while maintaining significant economic ties to Indonesia.

Implications for Indonesian Citizens Abroad

1. Reevaluation of Tax Status: WNI staying abroad for extended periods must now meet specific conditions to be considered foreign tax subjects. These include demonstrating permanent residence abroad and showing that their center of vital interests has shifted outside Indonesia ¹

   Source 1

   https://nasional.kontan.co.id/news/pemerintah-tutup-celah-akal-akalan-status-wajib-pajak
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2. Compliance Requirements: The regulation implies that Indonesian citizens must carefully assess their tax obligations under the new framework, potentially requiring professional advice to navigate the complex criteria ³

   Source 3

   https://nasional.kontan.co.id/news/ditjen-pajak-perjelas-status-pajak-diaspora-indonesia
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3. Impact on Diaspora Community: The new regulation affects Indonesian diaspora communities by potentially maintaining their tax obligations to Indonesia even after prolonged residence abroad ²

   Source 2

   https://finance.detik.com/berita-ekonomi-bisnis/d-8272059/lama-kerja-di-luar-negeri-wni-belum-tentu-lolos-dari-pajak-ri
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Expert Analysis

Tax expert Bawono Kristiaji from Danny Darussalam Tax Center (DDTC) notes that the new regulation represents both an update and alignment with previous laws, while introducing more technical and operational clarity to tax subject determination ¹

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