Executive Briefing · Tax Controversy
Received an SP2DK? A Structured Approach to the First Response
An SP2DK is a request for explanation, not an assessment. How the first response is prepared can shape what follows.
PrimeTax Editorial Team
SP2DK Assistance
SP2DK Assistance in Indonesia
Structured analysis and response preparation for SP2DK letters — accurate, supported, and consistent with the positions your company may need later.
Who this is for
Typical Clients
Companies that received an SP2DK
Businesses asked to explain data held by the tax office.
Finance managers
Teams responsible for the response and its supporting records.
Group CFOs
Leaders needing a view of exposure and next steps.
Common issues
What Typically Needs Attention
- Data differences
- Third-party data that does not match reported figures.
- Timelines
- Response periods stated in the letter.
- Consistency
- Explanations that hold at later stages.
- Escalation risk
- The possibility of an audit if the response is not accepted.
Self-assessment
Questions for Your Finance Team
If any answer is uncertain, it may be worth a focused review.
- 01
Has the data source been identified?
- 02
Have differences been reconciled to internal records?
- 03
Have explanations been separated from corrections?
- 04
Is the response consistent with filed returns?
Engagement process
How We Work
- 01
Understand
Review the letter or assessment, deadlines, and the facts behind the issues raised.
- 02
Assess
Analyse the regulatory basis, available evidence, and the strength of each position.
- 03
Advise
Recommend a response strategy and prepare submissions for management approval.
- 04
Support
Assist through discussions, follow-up requests, and subsequent stages as agreed.
FAQ
Frequently Asked Questions
Does an SP2DK mean we owe additional tax?
Not necessarily. It is a request for explanation. Whether additional tax is due depends on the facts and on whether the explanation is accepted.
Discuss Your SP2DK.
Share the context of your matter. We will propose a scope and approach for an initial discussion.