Tax Office Frequently Loses in Court, Enforcement Revenue Deposits Rp2.7 Trillion

The win rate of the Directorate General of Taxes (DJP) of the Ministry of Finance in tax dispute cases remains very low and continues to fall short of targets year after year. In the DJP Performance Report 2025, the win rate in the tax court was only 37.50% out of a total of 14,360 cases last year, both in appeals and lawsuits. However, the target for 2025 is 45% of the grand total of court decisions. The realisation of this win rate has even declined compared to the previous year. In 2021, the win rate was 43.25%, then in 2022 it became 44.8%, in 2023 it was 41.14%, and in 2024 it reached 44.14%. “Historically, over the last five-year performance period, this performance indicator has always failed to meet the target,” quoted from the DJP Performance Report 2025, on Monday (20/4/2026). The Directorate General of Taxes revealed that the main obstacle to the low win rate in court is the difference in perspectives between the Panel of Judges and Tax Officers. “The Panel of Judges makes decisions by prioritising the principle of justice, whereas Tax Officers adhere to applicable laws and regulations accompanied by available evidence/documents in the examination and objection process,” as stated in the DJP Performance Report 2025. To address the problem of the low win rate in handling tax disputes, DJP has implemented several strategies in 2025, such as case guidance that can be used by human resources (HR) handling tasks and functions in the field of dispute resolution for lawsuits or appeals. Then, developing the Tax Dispute Knowledge Base application which contains a repository of tax dispute data based on Tax Court Decisions. This application can be accessed by all HR across Indonesia handling appeal or lawsuit disputes. In addition, the Directorate General of Taxes has also collaborated with external parties to enhance the competence and capacity of Tax Officers involved in resolving appeal or lawsuit dispute processes. For 2026, the Directorate General of Taxes has also set four action plans to avoid losing many cases in court. Among them is improving the quality of feedback for HR or units involved in dispute handling, especially feedback for improving business processes or regulations. Then, increasing the quantity and quality of case dissections for ongoing appeal and lawsuit disputes in the tax court, as well as implementing centralisation of appeal and lawsuit dispute handling, so that all appeal or lawsuit dispute handling is at the DJP head office. The last is conducting training on speaking techniques for HR who play a role in handling appeal or lawsuit disputes. Regardless of that issue, the Directorate General of Taxes recorded a rapid increase in tax revenue from law enforcement results. The realisation up to the end of 2025 is Rp2.74 trillion, or an increase of 35.44% compared to the previous year. However, compared to the target, it is still far lower, because the target for 2025 is Rp4.18 trillion with a contribution of 0.14% from tax revenue from material compliance testing activities (PKM). The highest tax deposit from PKM results comes from supervision with a value of Rp57.41 trillion although the target is Rp118.94 trillion. Examination is in second place with a realisation of Rp55.35 trillion from a target of Rp113.94 trillion. As for collection, Rp20.54 trillion from a target of Rp20.45 trillion. “The realisation of tax revenue from PKM activities up to the end of December 2025 was recorded at Rp136.11 trillion with an achievement of 52.89% of the set target (Rp257.54 trillion),” said DJP.