Article 22 Tax Base for Marketplace Sellers

The Directorate General of Taxes says Article 22 income tax collection on domestic merchants through marketplaces began on 1 October 2026. The basis is PMK 37/2025, which the Ministry of Finance legal database records as in force from promulgation on 14 July 2025 and not yet amended.

The collectors are four operators appointed by a Director General decision dated 24 September 2026: PT Shopee International Indonesia, PT Global Digital Niaga Tbk, PT Tokopedia and PT Ecart Webportal Indonesia. The list appears in tax authority press release SP-23/2026, issued on 1 October 2026.

The same release says the government had earlier allowed an adjustment period until 31 October 2026, then set the start at 1 October 2026. According to Director General of Taxes Bimo Wijayanto, the timing adjustment did not change the substance of PMK 37/2025.

Tax base and tax point

The rate is 0.5% of gross turnover stated on the invoice, excluding VAT and luxury goods sales tax.

Article 8(2) of PMK 37/2025 says Article 22 tax falls due when the marketplace receives payment. The date the buyer’s money reaches the marketplace therefore decides the tax period, not the date funds reach the seller’s account. Merchants matching collection slips to bank statements will see a timing gap at each month end.

The attachment to PMK 37/2025 has a worked example on shipping. If delivery uses the store’s own courier, the shipping fee charged to the buyer is added to the seller’s tax base.

In that example, a computer priced at Rp15,000,000 is delivered by the store courier for Rp200,000. The collection is 0.5% of Rp15,200,000, or Rp76,000.

If delivery uses a third-party shipping company, the shipping fee is collected in the name of that company, separately from the seller.

Shipping fees borne by the seller are also not deducted from the seller’s tax base.

The same example shows room rental through a marketplace. The 0.5% collection becomes part of settling final income tax on rental of land or buildings, and the merchant pays the shortfall, 9.5% in that example. Article 8(6) requires the shortfall to be paid, and Article 9(2) requires it to be reported through the unified monthly income tax return.

Invoices and corporate buyers

Article 12(4) treats the invoice generated by the marketplace system as equivalent to an Article 22 collection slip. Under Article 12(3), the invoice shows items including the merchant’s account name, the buyer’s identity, discounts and the Article 22 tax amount.

Companies that buy supplies or services on a marketplace, and have been withholding income tax on those purchases, need to read that line. Article 10(3) says income already subject to Article 22 collection by the marketplace is not withheld or collected on again by other agents.

Invoices with a nil line are treated differently. Article 10(2) says income exempt from collection, for example where a seller files a statement of turnover up to Rp500 million, remains taxable. Withholding or collection then follows the general rules for that type of income.

A buyer’s tax team should therefore separate the two kinds of invoice before preparing its monthly withholding slips, and keep invoices showing collection as the basis for not withholding.

The Rp500 million threshold also has a deadline. An individual merchant whose turnover passes it must file a new statement by the end of the month in which the threshold is crossed, under Article 6(7).

Article 7(3) then requires the marketplace to collect from the start of the following month after receiving that statement. Turnover crossing the threshold on 20 November 2026, for example, means a statement by 30 November 2026 and collection from 1 December 2026.