Buyers of Patriot Bonds to Receive Immunity from Tax Prosecution

The government guarantees and protects purchasers of Patriot Bonds and Merah Putih Bonds issued by the Daya Anagata Nusantara Investment Management Agency (BPI Danantara) from legal action. This provision is set out in Article 50A paragraph (5) of Law Number 4 of 2026, which amends Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (UU P2SK). The guarantee is provided as long as the transactions are legitimate within the national financial system. “The state guarantees and protects the purchase of these special debt instruments as referred to in paragraph (a) from general criminal prosecution, special criminal prosecution, including tax crimes, and from civil lawsuits,” states Article 50A paragraph (5) of the P2SK Law. Article 50A paragraph (2) grants Danantara the right to issue debt securities or bonds, including special bonds such as Patriot Bonds and Merah Putih Bonds. The issuance of Patriot Bonds and Merah Putih Bonds is carried out by establishing policy strategies, management, and risk control, managed according to professional principles, accountability, and sound business considerations. Data on the purchase of these bonds cannot be used as a basis for taxation and cannot be used as evidence in court. “The provisions referred to in paragraphs (5) and (6) apply to transactions conducted on the primary market,” according to Article 50A paragraph (7). In the subsequent paragraph, investors are permitted to transfer and pledge Patriot Bonds and Merah Putih Bonds. These investors also include taxpayers who have participated in the tax amnesty programme and voluntary disclosure of taxpayers in accordance with statutory provisions. “Further provisions regarding the issuance of special debt securities as referred to in paragraph (2) letter b shall be regulated in a Government Regulation,” states Article 50A paragraph (10). The revision of the P2SK Law was previously passed by the House of Representatives (DPR RI) on 17 June 2026. The legislative document was also signed by President Prabowo Subianto on the same day.