To Prevent Unrest Among MSMEs and Retail Investors, IWPI Writes to Tax Director General Seeking Clarification
The Indonesian Taxpayers Association (IWPI) has officially sent a letter requesting written clarification to the Director General of Taxes, c.q. the Director of Tax Regulations I, on 7 July 2026. The letter, numbered 001/IWPI-DJP/VII/2026, seeks clarity on the status of financial instrument and investment transfer transactions in relation to a taxpayer’s gross turnover limit, specifically referring to the provisions of Article 58 of Government Regulation (PP) Number 20 of 2026.
In the letter signed by IWPI Chairman Adv. Rinto Setiyawan, the request for clarification covers five types of transaction instruments. These five transactions include the buying and selling of shares on the Indonesia Stock Exchange, buying and selling of crypto assets through official providers, buying and selling of tradable Government Securities, foreign exchange transactions, and buying and selling of gold bullion through official institutions.
IWPI highlighted the growing differences in interpretation among the public regarding whether the transaction value of transferring these investment instruments is calculated as gross turnover belonging to the fund owner (investor) or as gross turnover belonging to business actors, such as securities firms, platforms, and banks. According to IWPI, a clear distinction is needed between a taxpayer as a personal asset owner and a business actor who earns income from fees, spreads, or commissions.
The uncertainty in interpreting the object of gross turnover is considered to have caused unrest among MSME players and retail investors. IWPI is concerned that without official clarification from the tax authority, this situation could trigger legal uncertainty, differing treatment among tax officials, and potential discretion that risks reducing public trust in the tax administration.
As an illustration of the problem, IWPI cited the case of a business owner named Mr A who runs an MSME bakery with an annual turnover of Rp3 billion. If Mr A personally conducts foreign exchange transactions worth Rp5 billion in a year, the question arises whether the value of these personal transactions must be combined with his bakery’s business turnover when determining the gross turnover limit under Article 58 of PP Number 20 of 2026.
Through the letter, IWPI requested written clarification from the Directorate General of Taxes on the following six key questions: whether the transaction value of share trading on the Indonesia Stock Exchange by retail investors constitutes the taxpayer’s business gross turnover or is an asset transfer transaction subject to a separate tax regime; whether the transaction value of crypto assets, tradable government bonds, foreign exchange, and gold bullion by individual taxpayers constitutes the taxpayer’s gross turnover or is a personal investment instrument transfer transaction; whether the gross turnover for these transactions lies with the business actor/provider, insofar as the party earns income from the business activity of organising the transactions; in the case of an individual taxpayer owning an MSME with a turnover below Rp4.8 billion per year, whether the value of personal share, crypto asset, government bond, foreign exchange, and gold bullion transfer transactions must be combined into the MSME’s business gross turnover; whether the intensity, frequency, profit-seeking motive, or nominal value of a transaction can automatically change a personal asset transfer transaction into business gross turnover, even if the taxpayer does not act as a business actor providing goods and/or services to customers; and whether gross turnover in the context of a specific taxpayer must still be limited to income from business activities and/or independent work, not the entire value of personal asset mutations, transfers, or conversions.
IWPI Chairman Rinto Setiyawan stated that the association hopes the official clarification from the Directorate General of Taxes will provide an objective boundary between asset transfer transactions by investors or customers and business activities conducted by official providers. He added that this would provide legal certainty for the public, uniform guidelines for tax officials, and minimise potential differences in interpretation in the field. The request letter was also copied to a number of key stakeholders in the financial and taxation sectors, including the Minister of Finance, the Secretary General of the Ministry of Finance, the Head of the Fiscal Policy Agency, the Inspector General of the Ministry of Finance, the Director General of Taxes, the Chairman of the OJK Board of Commissioners, the Governor of Bank Indonesia, the President Director of the IDX, KSEI, KPEI, and the Chairman of Commission XI of the Indonesian House of Representatives.