MoF Regulation No. 191/PMK.010/2015 dated October 15, 2015

FIXED ASSETS REVALUATION FOR TAX PURPOSES FOR APPLICATION IN 2015 AND 2016

Taxpayer may conduct fixed assets revaluation for tax purposes with special treatment when such application is applied to DGT starting from the effective date of this regulation to 31 December 2016.
Such special treatment is final income tax rate:

1. 3%, for application up to 31 December 2015;
2. 4%, for application from 1 January 2016 to 30 June 2016; or
3. 6%, for application from 1 July to 31 December 2016.

Which will be applied to excess amount of fixed assets revaluation value or estimated appraisal value to origin fiscal book value.
Fixed assets revaluation value must be stated by public appraisal company or appraiser who have license from government. Such value must be set no later than:

1. 31 December 2016, for application submitted up to 31 December 2015;
2. 30 June 2017, for application submitted from 1 January 2016 to 30 June 2016; or
3. 31 December 2017, for application submitted from 1 July 2016 to 31 December 2016.

This provision may be applied to domestic taxpayer, permanent establishment and individual taxpayer, who manage accounting record, including:

1. Taxpayer who obtain permission to manage accounting record in English and US dollar currency; and
2. Taxpayer who at the date of revaluation has not passed 5 years period from last revaluation under Minister of Finance Regulation No. 79/PMK.03/2008.

Revaluation may be applied to part of or all tangible fixed assets in Indonesia owned and used for obtaining, collecting and maintaining income which are tax object. Another revaluation will not be allowed before 5 years period starting from date of revaluation under this regulation.
Revaluation value must be based on market value or fair value of fixed assets at the time of revaluation. When such revaluation value is different with actual condition, DGT may restate market value or fair value of the assets.
Application of fixed assets revaluation for tax purposes can be submitted by taxpayer who:

1. Already revalued its fixed assets but not yet used for tax purposes, following condition will be applied:
   1. Revaluation conducted in 2015 for application submitted in 2015; or
   2. Revaluation conducted in 2016 for application submitted in 2016; or
2. Has not revalued its fixed assets.

For taxpayer who already revalued its fixed assets but not yet used for tax purposes, the application must be attached with:

1. Tax payment form as evidence for payment of income tax on revaluation.
2. List of revalued assets.
3. Copy of public appraisal company or appraiser license legalized by authorized government institution.
4. Report of fixed assets revaluation issued by public appraisal company or appraiser; and
5. Latest financial statement before revaluation of fixed assets.

For taxpayer who has not revalued its assets, taxpayer may use estimated market value or fair value of fixed assets for submitting application with following documents:

1. Tax payment form as evidence for payment of income tax on revaluation.
2. List of revalued assets.

Then taxpayer must submitting another documents as follow:

1. Tax payment form as evidence for payment of income tax on revaluation when there is underpayment of income tax.
2. List of revalued assets.
3. Copy of public appraisal company or appraiser license legalized by authorized government institution.
4. Report of fixed assets revaluation issued by public appraisal company or appraiser; and
5. Latest financial statement before revaluation of fixed assets.

Such documents must be submitted no later than:

1. 31 December 2016, for application submitted up to 31 December 2015;
2. 30 June 2017, for application submitted from 1 January 2016 to 30 June 2016; or
3. 31 December 2017, for application submitted from 1 July 2016 to 31 December 2016.

After reviewing its accuracy and completeness, DGT will issue approval letter on fixed assets revaluation within 30 days since application is received.
Income tax must be paid before application is submitted to DGT.
When value in appraisal report is higher than taxpayer estimation, such difference will subject to final income tax amounting to:

1. 3%, for payment of income tax before 31 December 2015;
2. 4%, for payment of income tax from 1 January 2016 to 30 June 2016;
3. 6%, for payment of income tax from 1 July to 31 December 2016; or
4. 10%, for payment of income tax in 2017.

When value in appraisal report is lower than taxpayer estimation which resulting tax overpayment, such tax overpayment will be considered as tax should not be payable.
For taxpayer who maintain its accounting in English and USD currency, excess amount in revaluation for income tax basis must be converted to IDR by using exchange rate set by minister of finance decision at the date of payment.
When taxpayer who does not revalue its assets by using appraisal services or does not submit the required documents within time period as abovementioned, such application is considered as cancellation and income tax paid will be considered as tax should not be payable.
Taxpayer who get approval from DGT in 2015, depreciation calculation will be as follow:

1. Fiscal depreciable basis as revaluation value.
2. Fiscal useful life of fixed assets will be set to the first year for the group of assets; and
3. Depreciation calculation will be started since 1 January 2016.

Taxpayer who get approval from DGT in 2016 or 2017, depreciation calculation will be as follow:

1. Fiscal depreciable basis as revaluation value.
2. Fiscal useful life of fixed assets will be set to the first year for the group of assets; and
3. Depreciation calculation will be started from month of revaluation.

When taxpayer transfer its fixed assets:

1. Group 1 and 2 of fixed assets which already got approval for revaluation before end of its useful life; or
2. Group 3, 4 building and land which already got approval for revaluation before 10 years.

On excess value of revaluation to formerly fiscal book value will be subject to final income tax with highest rate at the time of revaluation deducted by tax paid. Such tax must be paid within 15 days after end of month of the assets transferred.
Such provision will not be applied when:

1. Such transfer is a force majeure under government regulation or judicial verdict;
2. Such transfer related to merger, business combination or expansion approved by DGT; or
3. Such assets are retired because of badly damage and cannot be repaired.

Difference of transfer value and its fiscal value at the time of transfer will be considered as gain or loss under income tax law.

Excess amount on revaluation value over commercial book value after deducted by income tax must be recorded under “taxpayer’ excess amount of fixed assets revaluation dated…” account in equity in commercial financial statements.

Bonus stock or capitalization to capital stock of excess amount of revaluation assets in equity will not be considered as tax object under income tax law and government regulation No 94 year 2010 article 2 letter b.

When such excess amount according fiscal is higher than commercial, bonus stock or recapitalization which considered as non tax object only valid up to commercial amount.

Further provision under this regulation will be set by DGT Regulation.

At the effective date of this regulation, taxpayer who already submitted fixed assets revaluation application under Minister of Finance Regulation No. 79/PMK.03/2008 and not yet obtained any approval, may resubmitted its application under this regulation.

​This regulation will be effective on October 20th, 2015.