Tax Penalty Relief by Document Type Under KEP-239/PJ/2026
KEP-239/PJ/2026 reduces or waives administrative sanctions through 2027, but not every sanction gets 100%. The rate depends on the type of document, its issue date, and when the tax or part of the sanction is paid.
Key points
- Tax collection letters issued before 8 October 2026 for sanctions under Articles 7, 8 and 9 of the KUP Law get at most 90%, and the remaining 10% must be paid.
- Sanctions already paid are not reduced.
PMK 71/2026, issued on 29 September 2026, amends PMK 118/2024 and inserts Article 27A, which lets the Director General of Taxes reduce or waive administrative sanctions on applications made within two years. It is implemented by KEP-239/PJ/2026, issued and effective on 8 October 2026.
Summaries in circulation say sanctions are waived in full until year-end. That holds for only some cases. The attachment to KEP-239 sets the rate by document type, and the relevant date differs too.
Returns filed or corrected now
The first group covers sanctions for late filing, voluntary correction, or late payment. It applies to annual income tax returns up to tax year 2025 and periodic returns up to September 2026. Late filing and correction must show tax underpaid.
| Filing date | Relief |
|---|---|
| 8 October to 31 December 2026 | 100% |
| 1 January to 31 March 2027 | 50% |
| 1 April to 30 June 2027 | 25% |
The conditions differ. For late filing, the filing date counts. For corrections and late payment, the return must be both filed and paid within the period.
Documents issued before 8 October
Here 100% is not always available. Collection letters for sanctions under Articles 7, 8 and 9 of the KUP Law issued before 8 October 2026 get 90% if the taxpayer pays 10% of the sanction between 8 October and 31 December 2026, or 75% if 25% is paid between 1 January and 30 June 2027.
Assessments issued before that date with no objection follow the date the principal is settled: 100% by 31 December 2026, 50% by 31 March 2027, and 25% by 30 June 2027. Where the principal was settled before 8 October, the rate is 90% or 75%, with part of the sanction payable.
For audit assessments issued after 8 October, the test moves to months from the assessment date: settlement within one month gets 100%, within two months 50%, and later 25%, all by 30 June 2027.
Conditions that are easy to miss
Article 23(5)(a) requires the underlying tax to be settled. The fourth dictum adds a stamped statement that the sanction arose from oversight or not through fault, and a statement of no lawsuit or other legal remedy, or proof of withdrawal.
Relief covers only sanctions not yet paid. A company that has already paid gets no refund through this route. Sanctions in collection letters under Articles 25(9), 27(5d) and 27(5f) of the KUP Law are excluded by Article 21A.
Before the year ends
First, list open assessments and collection letters in Coretax, marking the sanction type and issue date. Then map each one to the tables in the KEP-239 attachment. Then work out the cash: settling principal before 31 December gives a very different result from January.
Applications themselves may follow up to 1 October 2028.
Frequently asked questions
Is the relief automatic?
No. The third dictum requires an application to the Director General of Taxes by 1 October 2028, with one application for each assessment or collection letter.
We have an objection pending. Can we apply?
Yes, if the objection is withdrawn and the withdrawal approved. Article 32(3) then closes the route for reducing an incorrect assessment, so weigh the underlying dispute first.