Tax residency of a foreigner in Indonesia: when you are a tax resident and what follows

This page is for a foreigner who lives in Bali, stays for long periods or plans to, and wants to know whether Indonesian law treats the person as a tax resident (subjek pajak dalam negeri, SPDN) or as a non-resident (subjek pajak luar negeri, SPLN), and what follows. It states what the texts say, with the article, and says where they are silent or differ. It is general information, not legal advice and not tax advice. Nothing here is a way to pay less tax than the law requires.

We used the texts in force on 6 October 2026: UU 7/1983 on income tax (UU PPh) as amended, in particular Pasal 2 as rewritten by UU 6/2023 (Pasal 111 angka 1), Pasal 2A inserted by UU 10/1994, Pasal 4 as rewritten by UU 7/2021 (the harmonisation law, Pasal 3 angka 1), and Pasal 24 and 26; PP 55/2022 (its status record lists one amendment, PP 20/2026, which changes other articles); PMK 81/2024 as amended up to PMK 1/2026 (the amendments we read leave the articles used here as they were); the regulation of the Director General of Taxes (DJP) PER-23/PJ/2025 of 9 December 2025 on determining resident and non-resident status; and PMK 112/2025 of 30 December 2025 on tax treaties. We also read the elucidations (penjelasan) of UU 6/2023 and UU 10/1994 on the articles cited.

Two older rules no longer govern the points on this page. PER-43/PJ/2011 and PER-2/PJ/2009 were revoked by PER-23/PJ/2025 (Pasal 12). Pasal 7 to 13 of PMK 18/2021, which held the rule for foreigners with expertise, were revoked by PMK 81/2024 (Pasal 483), in force since 1 January 2025.

Not covered: tax rates, the tax-free income threshold (PTKP) and what counts as income; withholding by payers such as employers and tenants; the taxes of buying, leasing and selling (see the pages on taxes and official costs of buying, on selling and leaving and on tax deadlines); the tax law of your home country; companies, including a PT PMA, whose own residence follows from where they are set up; and the tax treatment of a Golden Visa or of a financial-centre zone (see the section on rules that moved). The dates and filing of the annual return are on the page on tax deadlines, the tax number on the page on NPWP, the bank's declaration of tax residence on the page on bank accounts, the permits on the pages on visas and stay and on KITAS and KITAP, and leaving Indonesia on the pages on taxes when leaving and on selling and leaving.

The income tax law divides tax subjects into domestic (resident) and foreign (non-resident) ones (UU PPh Pasal 2(2)). An individual, Indonesian or foreign, is a domestic tax subject who (1) has a home in Indonesia, (2) is in Indonesia more than 183 days in a period of 12 months, or (3) is in Indonesia in a tax year with the intention to live in Indonesia (Pasal 2(3)(a), as rewritten by UU 6/2023 Pasal 111 angka 1). The list joins the three with "or", so passing one is enough. PER-23/PJ/2025 repeats the three tests for "orang pribadi, baik WNI maupun WNA" (Pasal 3 huruf a).

The home test. PER-23/PJ/2025 Pasal 4(1) says an individual has a home in Indonesia who (a) lives at a place in Indonesia that the person controls or can use at any time, that is owned, rented or available for use, and that is not a stopover; or (b) has the main centre of activity in Indonesia, which the person uses as the centre of personal, social, economic or financial affairs; or (c) carries on daily habits or activities in Indonesia, including hobbies. The three are joined by "or". The place where a person lives is fixed by the Director General of Taxes according to the actual situation (UU PPh Pasal 2(6)). The elucidation adds that the place of residence is judged on the facts and not on formal grounds alone, and names among the things to weigh the domicile, the address, the place where the family lives and the place of the main business (UU 6/2023, Penjelasan Pasal 111 angka 1, Pasal 2 ayat (6)).

On the words, a home in Bali where you actually live (bermukim), and that you own or rent and can use at any time, is within limb (a), and the text sets no minimum number of days for it. A place that you only own or can use, but do not live in, is not enough on these words, and a stopover does not count. We found no definition of a "stopover" (tempat persinggahan). The 183-day test and the test of intention follow in the next sections.

The 183 days are counted over a period of 12 months, whether the days are in a row or not, and a part of a day counts as a whole day (PER-23/PJ/2025 Pasal 4(2)). A person counts as being in Indonesia when physically present in the country at that time, according to the actual situation (Pasal 4(4)). Nothing in the article ties the count to a visa or permit, so days on a visit permit are counted like days on an ITAS.

The article says "jangka waktu 12 (dua belas) bulan", a period of 12 months. The elucidation of Pasal 2(3) huruf a says the days need not be consecutive and are determined by the number of days the person is in Indonesia "dalam jangka waktu 12 (dua belas) bulan sejak kedatangannya di Indonesia", in a period of 12 months from the person's arrival (UU 6/2023, Penjelasan Pasal 111 angka 1). It does not say whether a new period starts when the person leaves and comes back; the test of intention, by contrast, speaks of "a tax year". The regulation points to worked examples in its annexes A and B. The copy on the DJP site has no annexes, so we state no counting method beyond these texts.

The third test needs no 183 days. A person who in a tax year is in Indonesia with the intention to live here is a domestic tax subject, from the time stated in the section on start and end. The intention "can be proven" by the documents in the next table (Pasal 4(3)); the elucidation says that whether a person has the intention is weighed according to the circumstances ("ditimbang menurut keadaan").

The tax duty of a resident individual starts when the person is born, is present in Indonesia or intends to live there, and ends on death or on leaving Indonesia for good (UU PPh Pasal 2A(1), inserted by UU 10/1994 Pasal I angka 3). The elucidation of that paragraph says that for an individual who is in Indonesia more than 183 days in 12 months the duty starts on the first day the person is in Indonesia, and that leaving for good is judged on the concrete facts when the person leaves: if there is concrete evidence of the intention to leave Indonesia for good at that time, the person is no longer a domestic tax subject from then (UU 10/1994, Penjelasan Pasal 2A ayat (1)). It names no documents. PER-23/PJ/2025 Pasal 10 says this start and end apply after the status has been determined under its tests, and its Pasal 8 uses the words "leaving Indonesia for good" for Indonesian citizens who become non-residents.

If the duty covers only part of a tax year, that part replaces the tax year (Pasal 2A(6)). The annual return is then for the part of the year and is due within 3 months at most after the end of that part (PMK 81/2024 Pasal 162(1) huruf b angka 2 and Pasal 170(1)).

The administrative fine for a late return is not imposed on an individual foreigner who no longer lives in Indonesia and/or has not been in Indonesia more than 183 days in 12 months (PMK 81/2024 Pasal 179(3) huruf c). The text does not say from which date, or whether the return is then still due. The return for the part of the year and the other taxes of leaving are on the page on taxes when leaving. Deleting the tax number, and the checks before leaving, are in the section If you leave Indonesia: stay permit, exit and tax number of the page on selling and leaving.

Tax withheld from a non-resident under Pasal 26 is final, except tax withheld from an individual who changes status to a resident taxpayer (UU PPh Pasal 26(5) huruf b, as rewritten by UU 6/2023).

A resident is taxed on income "baik yang berasal dari Indonesia maupun dari luar Indonesia", whether it comes from Indonesia or from outside it (UU PPh Pasal 4(1), as rewritten by UU 7/2021 Pasal 3 angka 1). A resident who has paid or owes tax abroad on income from abroad may credit that foreign tax against the Indonesian tax of the same tax year, but not above the tax calculated under the Indonesian law (Pasal 24(1) and (2)). A ministerial regulation sets how the credit is applied (Pasal 24(6)); we did not map it. A treaty can change who taxes what, as described in the section on treaties.

For the limit of the credit the law fixes where some income comes from: rent of immovable property, and gains on transferring immovable property, come from the country where the property is; fees for services, work and activities come from the country where the payer is established or is (Pasal 24(3) huruf c, d and g). Those rules are written for the credit limit, and we found no text that says they define "income from Indonesia" for every purpose.

A non-resident is taxed on income from Indonesia (Pasal 2(4) huruf a and b). Whoever pays it in Indonesia, such as a government body, a resident taxpayer, the organiser of an activity or a permanent establishment, withholds tax under Pasal 26(1) on dividends, interest, royalties, rent and other income from the use of property, fees for services, work and activities, prizes, pensions and other listed items, and under Pasal 26(2) on a sale of assets in Indonesia (as rewritten by UU 6/2023 Pasal 111 angka 2). The rate is set in the article and is not covered here. A non-resident individual who runs a business or activity through a permanent establishment in Indonesia is also a foreign tax subject (Pasal 2(4) huruf a and (5)).

What it says. A foreigner who has become a resident is taxed only on income received or earned from Indonesia, if the person has certain expertise under the regulations, and the rule runs for 4 tax years counted from becoming a resident (UU PPh Pasal 4(1a), as rewritten by UU 7/2021; PP 55/2022 Pasal 3(1); PMK 81/2024 Pasal 442(2)). Income from Indonesia includes income from work, services or activities in Indonesia that is paid outside Indonesia (Pasal 4(1b); PMK 81/2024 Pasal 442(3)). The rule does not apply to a foreigner who uses a tax treaty for income from the treaty country (Pasal 4(1c); PMK 81/2024 Pasal 442(4) and Pasal 445), so the person chooses between the two.

Who it covers. The texts name two groups: foreign workers who fill certain posts, and foreign researchers (PP 55/2022 Pasal 4(1); PMK 81/2024 Pasal 443(1)). The worker must be employed by an employer and fill one of the "certain posts" (pos jabatan tertentu) that the manpower minister has set for foreign workers (PP 55/2022 Pasal 4(2) huruf a; PMK 81/2024 Pasal 443(2) huruf a). Annex DDDD of PMK 81/2024 lists the posts by ISCO/KBJI code: 25 posts, among them chemists, civil, mechanical, electrical and telecommunications engineers, graphic and multimedia designers, university lecturers, systems analysts, software and web developers and application programmers. The expertise must be in science, technology or mathematics, proven by an expertise certificate from a body designated by Indonesia or by the person's home country, a diploma, and/or at least 5 years of work experience in the field (the three are joined by "and/or"), and the person must have a duty to transfer knowledge (PP 55/2022 Pasal 4(3); PMK 81/2024 Pasal 443(3)). The lists we read name no other group: they do not mention investors, property owners, retirees, remote workers or the self-employed.

How it is claimed. The foreigner applies to the DJP (PMK 81/2024 Pasal 446(1)) and must have filed the annual returns for the last 2 tax years that were due (Pasal 446(2)). The DJP issues an approval or a rejection within 10 working days at most after the receipt for the application is issued (Pasal 446(4)). With an approval the person reports income from Indonesia only in the annual return; with a rejection, income from Indonesia and from abroad (Pasal 447(1)). The 4 years are counted from the first time the person became a resident, and the end date stays the same if the person leaves Indonesia (Pasal 444).

PP 55/2022 Pasal 5 leaves the procedure to a ministerial regulation. PMK 81/2024 Pasal 442 to 447 is that regulation; the amendments to PMK 81/2024 that we read (PMK 11/2025, 53/2025, 54/2025 and 1/2026) did not change these articles or the annex.

A tax treaty (Persetujuan Penghindaran Pajak Berganda, P3B) is an agreement between Indonesia and another country or jurisdiction to avoid double taxation and prevent tax evasion (PER-23/PJ/2025 Pasal 1 angka 2; PMK 112/2025 Pasal 1 angka 6). The Government may make and apply such agreements (PP 55/2022 Pasal 48 and 49). A treaty applies to individuals and companies that are tax subjects of Indonesia or of the partner country, shown by a certificate of domicile (PP 55/2022 Pasal 50(1)). The DJP site lists Indonesia's treaties with the text of each; we do not copy the list or any rate. Whether a treaty is in force with your country, from which date and what it says, you read there.

What a treaty can change. Where there is a treaty, the tax on a resident's income from abroad and on a non-resident's income from Indonesia can be charged as the treaty provides (PMK 112/2025 Pasal 2(2)). The benefits the regulation names are a lower withholding rate, taxing by the country of residence only, exemption from Indonesian income tax, and a different time test for a permanent establishment (Pasal 2(6)). A person who abuses a treaty, that is, who acts to reduce, avoid or delay tax against the purpose of the treaty, has no benefit (Pasal 2(4) huruf c, (7) and (8)). A person who is an Indonesian tax subject cannot claim the benefits that a treaty gives a non-resident (Pasal 2(4) huruf a).

The tie-breaker. A person can be a resident under the laws of two countries. Where Indonesia has a treaty with the other country, the treaty decides the status (PER-23/PJ/2025 Pasal 11). In the treaty texts we read on the DJP site (Russia, China and Singapore, Article 4(2)) the test for an individual runs in order: the country where the person has a permanent home available; if there is one in both, the country with which personal and economic relations are closer (centre of vital interests); if that cannot be decided, or there is no permanent home in either, the country where the person has a habitual abode. The Singapore text then looks to nationality and, last, to agreement between the tax authorities; the Russian and Chinese texts go straight to agreement between the authorities. Other treaties may differ, so read the article on residents (usually Article 4) of the treaty with your country. These tests are the treaty's own and are not the three tests of Indonesian law above.

A resident is a tax subject. The person becomes a taxpayer (Wajib Pajak) once income from Indonesia or from abroad exceeds the tax-free income threshold (PER-23/PJ/2025 Pasal 4(5); UU 6/2023, Penjelasan Pasal 111 angka 1, Pasal 2 ayat (2)). The same elucidation says that a resident taxpayer must file the annual return, while a non-resident taxpayer need not, because the tax is met by final withholding. The number and the registration are on the page on NPWP. The annual return of an individual (SPT Tahunan) is due within 3 months at most after the end of the tax year (PMK 81/2024 Pasal 169(1)). The date, the extension, the portal and the late-filing rules are on the page on tax deadlines and are not repeated.

What goes into the return. The annual income tax return states, besides the identity data, the turnover, the total income including income that is not an object of tax, the taxable income, the tax owed, the tax credits, the shortfall or overpayment, and the total of assets and liabilities (PMK 81/2024 Pasal 164(2)). The text we read does not leave income or assets abroad out of these totals. The return is filled in correctly, completely and clearly, in Indonesian, with Latin letters, Arabic numerals and the rupiah as the unit of currency, and is signed (Pasal 161(1)). A foreigner who is approved for the four-year rule reports Indonesian income only (Pasal 447(1)).

Which tax office. PER-17/PJ/2025 lets the Director General of Taxes assign certain taxpayers to the large, special and madya tax offices, and lists among the offices of the Jakarta special regional office the Tax Office for Companies and Foreigners (KPP Badan dan Orang Asing), for, among others, "warga negara asing yang sudah menjadi subjek pajak dalam negeri", foreigners who have become domestic tax subjects (Pasal 2(1), (2) and (3) huruf b angka 8). The text says "dapat", may, and lists nationality among the criteria. We found no text that says which foreigners are assigned there; ask when you register (page on NPWP).

"Resident" means different things in different laws. In the Foreign Exchange Act a resident is a person domiciled, or planning to be domiciled, in Indonesia for at least one year (UU 24/1999 Pasal 1 angka 3), a one-year test that the pages on financing and on selling and leaving use for lending and for foreign currency. It is not the tax test.

A stay permit decides what you may do in Indonesia. For tax it is only one piece of evidence of the intention to live here, and only if it is valid for more than 183 days (PER-23/PJ/2025 Pasal 4(3)); the tests also look at the days in Indonesia and at a home, whatever the permit. The bank's declaration of tax residence when you open an account is a separate duty under the law on exchange of financial account information (page on bank accounts).

On 1 January 2025 PMK 81/2024 took over the rule for foreigners with expertise from PMK 18/2021 (Pasal 483 and 484). On 9 December 2025 PER-23/PJ/2025 replaced PER-43/PJ/2011 and PER-2/PJ/2009 as the rule on determining resident and non-resident status. On 30 December 2025 PMK 112/2025 set the procedure for treaties (in force 31 December 2025). UU 6/2023 rewrote Pasal 2 of the income tax law (Pasal 111 angka 1): the test for an individual now reads "baik WNI maupun WNA", Indonesian or foreign, and a route for Indonesian citizens living abroad to be non-residents was added (Pasal 2(4) huruf c).

UU 4/2026, in force since 17 June 2026, inserts Pasal 248A into the financial sector law: the Government sets up an Indonesia International Financial Centre (Pusat Finansial Internasional Indonesia), business activities there get special tax treatment and special tax facilities, and a law on running it is to be made within 3 months of UU 4/2026 being promulgated (Pasal 248A(6) and (7)). Press reports of 21 July 2026 (not official texts) say the House of Representatives passed that law on that day and that it gives non-resident tax treatment to some Golden Visa holders connected to the zone. We could not confirm this: the House page refused our request, and we did not work around it; the Ministry of Finance page returned no text; and we found no promulgated text in the BPK database on 6 October 2026. This page does not cover it. Read the official text before relying on it.

Do I pass any of the three tests in this tax year, and from which date? How many days have I been in Indonesia in the last 12 months, counting a part of a day as a whole day?

Which documents show an intention to live here, and do I hold any (a permit valid for more than 183 days, a contract, a lease)?

Am I also a resident of another country? Is there a treaty with it, and what does its article on residents say?

Is my post, or my research role, within the four-year rule, and have I filed the annual returns for the last two tax years that were due?

Do I need a certificate of domicile for the country my income comes from, and can I get it through the taxpayer portal?

At which tax office am I registered, and what is my tax number (page on NPWP)?

When I leave: from which date am I a non-resident, do I file a return for part of the year, and do I delete my number (pages on taxes when leaving and on selling and leaving)?

The annexes A to E of PER-23/PJ/2025 (worked examples of the 183 days, of presence in Indonesia and of the tests for Indonesian citizens) are not in the copy on the DJP site, so the page gives no example from them.

Whether a new 12-month period of the 183-day test starts when a person leaves and comes back: the elucidation counts the 12 months "sejak kedatangannya di Indonesia", from arrival, and says no more.

The meaning of a "stopover" in the home test (Pasal 4(1) huruf a angka 3), and which documents count as "concrete evidence" of the intention to leave Indonesia for good.

Who sets the list of foreign researchers: PP 55/2022 Pasal 4(2) huruf b says the head of the research agency, and PMK 81/2024 Pasal 443(2) huruf b says the minister for research. The two texts differ and we found nothing that reconciles them.

Which parts of PER-25/PJ/2018 still apply. PMK 112/2025 has no article that revokes it, the DJP regulation database on 6 October 2026 shows it as active, and a DJP announcement says that forms and certificates issued under PER-25/PJ/2018 before PMK 112/2025 stay valid for the period they state. The announcement also says that, until the format is adjusted, the certificate of domicile of a resident generated in the core tax system may still be used.

How the foreign tax credit is applied now: we did not map the ministerial regulation under UU PPh Pasal 24(6).

The amount of the tax-free income threshold, rates, and the sanctions for a late or missing return: not covered.

Whether a treaty is in force with your country and what its article on residents says: read the text on the DJP site.

Which foreigners the DJP assigns to the Tax Office for Companies and Foreigners.

How the "certain posts" that the manpower minister sets for the four-year rule relate to the list in annex DDDD of PMK 81/2024: we did not compare the annex with the minister's own lists of posts.

The text of the law on the Indonesia International Financial Centre, and what it says on Golden Visa holders: see the section on rules that moved.