Coretax Reporting for Permanent Establishments (BUT): What Foreign Businesses Must Do

Coretax Reporting for Permanent Establishments (BUT)
Disclaimer: The information on this website is for general informational purposes only and does not constitute legal, investment, tax, or financial advice. While InvestinAsia strives for accuracy, regulations may change over time. We are not liable for actions taken based on this content. Please consult our experts for personalized advice.

If you operate in Indonesia as a Permanent Establishment or BUT, you must file your annual corporate income tax return through Coretax starting January 1, 2025. The system fully replaces e-Form and e-Filing under the supervision of Direktorat Jenderal Pajak.

The bottom line is clear. Every BUT must submit its annual corporate tax return using Formulir 1771 and report net taxable income subject to the 22 percent corporate income tax rate.

Failure to comply results in administrative sanctions under UU KUP and related Ministry of Finance regulations, including KMK 16/MK.4/2025.

Who Qualifies as a Permanent Establishment (BUT)?

Coretax Reporting for Permanent Establishments (BUT)
Coretax Reporting for Permanent Establishments (BUT) (pajak.go.id)

A foreign company becomes a BUT when it operates through a fixed place of business in Indonesia, typically exceeding six months. This includes representative offices conducting income-generating activities, project offices, or branches.

Before filing, you must confirm your PE status. Misclassification creates reporting gaps and exposes you to tax audits and sanctions.

Also read: Coretax Compliance Checklist for Foreign-Owned Companies (PT PMA)

Key Coretax Requirements for BUT

Coretax is not just a new portal. It introduces structured compliance steps.

You must:

  • Update NPWP registration data
  • Register a Person in Charge with valid KITAS if foreign
  • Activate an electronic tax certificate for digital signing
  • Prepare consolidated financial statements
  • Prepare SSP for PPh 26(4)
  • Prepare investment notification letters if applicable

No EFIN is required. Access uses OTP authentication through the DJP portal.

Understanding Form 1771 and BUT-Specific Attachments

BUT entities use special attachments within Form 1771.

Lampiran 12A

This attachment calculates PPh Article 26(4) on deemed profits. It allocates head office costs and determines taxable profit distribution to the foreign head office.

Lampiran 12B

This attachment reports reinvestment of taxable income. Proper disclosure may support exemption eligibility for certain reinvested amounts.

LampiranPurposeKey Inputs
12APPh 26(4) computationDeemed profit allocation, HO expenses
12BReinvestment reportingPost-tax reinvested income

Accuracy in these attachments directly affects your final tax payable.

Also read: How to Issue e-Faktur (VAT Invoice) in Coretax for PT PMA

Filing Timeline and Deadlines

The annual deadline remains April 30 of the following year. For fiscal year 2025, the deadline is April 30, 2026.

Late filing triggers a Rp1,000,000 administrative fine per return. This penalty applies once per SPT, regardless of delay duration.

If the return shows underpayment, additional monthly interest applies. The rate follows the prevailing Ministry of Finance rate, typically between 0.51 percent and 2.18 percent per month.

Additional Ongoing Obligations

Coretax reporting must align with monthly SPT Masa obligations, including:

  • PPN
  • PPh 21
  • PPh 23 and 25

You must also maintain audited financial statements, including balance sheet and profit and loss statements.

Non-compliance can escalate beyond fines. Intentional failure to report may result in criminal sanctions, including imprisonment of 3 to 12 months or fines up to twice the tax due.

Practical Reporting Flow in Coretax

The filing sequence typically follows:

  1. Access Coretax via DJP portal
  2. Start with Induk SPT
  3. Complete attachments such as 12A and 12B
  4. Review prepopulated tax credits
  5. Submit electronically
  6. Pay via billing code or tax deposit

If penalties arise, payment is processed through billing after a tax collection letter is issued.

Also read: How to Report Withholding Tax (PPh 26) for Foreign Parties in Coretax

Why Foreign Businesses Struggle With Coretax

Most expatriate-led businesses face three issues:

  • Complex PPh 26(4) calculations
  • Documentation gaps between head office and Indonesian branch
  • Inconsistent monthly and annual reconciliation

These issues increase audit risk and delay compliance.

As tax consultants assisting foreign investors daily, we see that proper structuring from the beginning prevents costly corrections later.

Also read: How InvestinAsia Helps Foreign Companies File Taxes in Coretax

How We Help You Stay Fully Compliant

At InvestinAsia, we guide you through every step of Coretax reporting. Our Indonesia tax consultant and compliance services ensure your BUT structure, Form 1771 filing, Lampiran 12A and 12B preparation, and monthly SPT alignment are accurate and audit-ready.

If you are an expatriate business owner or foreign investor operating in Indonesia, we help you reduce risk, avoid penalties, and focus on growth while we manage compliance.

Contact us now for FREE consultation and get a special offer!

 

FAQs: Coretax Reporting for BUT

1. Is Coretax mandatory for all Permanent Establishments?

Yes. Since January 1, 2025, all BUT must file their annual corporate income tax return through Coretax.

2. What is the corporate income tax rate for BUT?

The applicable corporate income tax rate is 22 percent on net taxable income.

3. What is Lampiran 12A used for?

Lampiran 12A calculates PPh Article 26(4) on deemed profits allocated to the foreign head office.

4. What happens if a BUT files late?

A Rp1,000,000 administrative fine applies per late annual return, plus possible interest if there is underpayment.

5. Do foreign directors need KITAS for Coretax registration?

Yes. If appointed as PIC, foreign nationals must have a valid KITAS and electronic tax certificate for digital signing.

Contact Us

if you are ready to start your life in indonesia or to think of discusing other options.

Tax Calculator
Calculate income tax PPh 21, 23, 4 paragraph (2), and VAT

Talk to Our Consultants

    Related Posts