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PrimeTax
IDEN

04 — Tax Controversy

Tax Controversy and Dispute Support

Respond to tax office enquiries and audits in a structured way, understand your position, and make informed decisions about objection and appeal.

Discuss Your SP2DK or Tax Audit

Client situations

When Companies Engage Us

An SP2DK has been received

A request for explanation of data requires a timely, accurate response. The way it is answered can affect whether an audit follows.

A tax audit has started

Audits involve document requests, discussions, and deadlines. Preparation and consistent communication help manage the process.

An assessment has been issued

Management must decide whether to accept, object, or pursue other remedies within statutory time limits.

A refund claim is pending

Refund requests typically trigger an examination. Records should be ready before the claim is filed.

Scope of assistance

What We Cover

SP2DK Assistance
Analysis of the data in question, preparation of the explanation, and supporting documentation.
Tax Audit Preparation and Assistance
Readiness review, document preparation, and support during audit discussions and closing conferences.
Tax Objection
Analysis of the assessment and preparation of the objection within statutory timelines.
Tax Appeal
Support with the appeal process at the Tax Court, subject to applicable representation requirements.
Tax Refund Assistance
Preparation of refund claims and support during the related examination.
Tax Dispute Strategy
Assessment of the merits, costs, and timelines of available remedies to support management's decision.

Engagement process

How the Work Is Structured

  1. 01

    Understand

    Review the letter or assessment, deadlines, and the facts behind the issues raised.

  2. 02

    Assess

    Analyse the regulatory basis, available evidence, and the strength of each position.

  3. 03

    Advise

    Recommend a response strategy and prepare submissions for management approval.

  4. 04

    Support

    Assist through discussions, follow-up requests, and subsequent stages as agreed.

Considerations

Regulatory and Technical Context

Statutory deadlines

Objections and appeals are subject to strict time limits under the General Provisions and Tax Procedures Law (KUP) and the Tax Court Law. Missing a deadline can remove a remedy entirely.

Consistency across stages

Positions and evidence presented at the SP2DK or audit stage may affect later stages. A consistent strategy from the start is important.

Representation

Representation before the tax office and the Tax Court is subject to specific requirements. The scope of PrimeTax's role is confirmed in each engagement.

Summary for general information only. Regulations are applied to the specific facts of each engagement.

How we present exposure to management

Likelihood
LowMediumHigh

Impact

Illustrative framework. Actual ratings depend on the facts of each engagement.

FAQ

Frequently Asked Questions

How quickly should we respond to an SP2DK?

Responses are expected within the period stated in the letter. Contact us as soon as it is received so there is time to analyse the data and prepare a considered response.

Can you guarantee the outcome of an objection or appeal?

No. Outcomes depend on facts, evidence, and the decision of the tax authority or court. We provide an assessment of the merits and risks so management can decide how to proceed.

Should we prepare for an audit before one is announced?

Yes, particularly before filing a refund claim or after significant transactions. Audit readiness reviews help identify gaps while there is still time to address them.

Related

Related Services and Insights

01

Tax Advisory

Structured review, planning, and written opinions that help management understand tax positions before material decisions are made.

Explore Tax Advisory
03

Transfer Pricing

Risk assessment, documentation, and benchmarking for related-party transactions under Indonesian transfer pricing rules.

Explore Transfer Pricing

Discuss Your SP2DK or Tax Audit.

Share the context of your matter. We will propose a scope and approach for an initial discussion.

Discuss Your SP2DK or Tax Audit