VAT on Foreign Digital Transactions Under PMK 49/2026
PMK 49/2026 appoints payment issuers to collect VAT on foreign digital goods and services. The collection document counts as a tax invoice, and the VAT can be credited if the conditions are met.
Key points
- A bill statement can serve as the document if it contains the data in Article 10(2).
- Transactions not yet collected on remain subject to VAT under Article 17.
PMK 49/2026 was issued on 14 July 2026 and took effect on promulgation, implementing Presidential Regulation 68 of 2025 on the tax collection system for foreign digital transactions (SPP-TDLN). It targets digital goods and services from abroad where VAT has not been collected by an appointed e-commerce business.
Article 3(2) brings in issuers as appointed third parties. Article 1(20) defines an issuer as a bank or non-bank institution providing services that facilitate payment. An issuer must first complete development and stabilisation periods under Article 4 and then be appointed by the Director General of Taxes, so collection on a given payment instrument depends on the issuer’s appointment status.
How it is calculated
Article 7(2) applies a formula of 11/111 to a price that already includes VAT. A charge of Rp1,110,000 means VAT of Rp110,000 on a base of Rp1,000,000. These figures are an illustration. For foreign currency, Article 7(4) uses the Ministerial exchange rate in force when SPP-TDLN confirms the transaction.
VAT becomes payable when the system operator confirms to the issuer, under Article 6. Article 8(2) requires data to be sent no later than payment authorisation, and Article 8(6) allows up to 1 day for confirmation.
Conditions for input VAT
Article 10(5) treats the collection document as equivalent to a tax invoice. Article 10(4) allows it to take the form of a bill statement. Article 10(6) ties the credit to two conditions: the email address or telephone number on the document is registered with the tax office, and the general crediting rules are met.
The first condition is easy to miss. A corporate card registered to a staff member’s personal email could lose the credit even though the VAT has been paid.
Where nothing has been collected
Article 17 confirms that VAT still applies where it has not been collected. VAT-registered companies therefore still need to review software subscriptions, digital advertising and cloud services paid abroad.
What finance teams should do
First, list foreign digital subscriptions and their payment instruments. Then align the email and telephone number on corporate cards with tax records. After that, keep bill statements containing the Article 10(2) data, because they support the input VAT.
In the month-end reconciliation, separate three groups: transactions collected by an e-commerce business, those collected by the issuer, and those not yet collected.
Frequently asked questions
Are all payments abroad covered?
No. Article 2(2) limits this to digital goods and digital services from outside the customs area. Article 5(1) excludes transactions where VAT is collected by an appointed e-commerce business.
What if a transaction is cancelled?
Article 16(1) lets the person charged reclaim VAT that should not have been collected, through the issuer to the system operator.