PU PMSE vs BUT in Indonesia 2025 – thresholds, taxable presence, and reporting obligations
December 24, 2025

Clarifying PU PMSE and BUT Status to Stay Compliant in Indonesia’s Digital Economy

In Indonesia’s rapidly expanding digital economy, knowing whether your business qualifies as a PU PMSE (foreign digital business) or a BUT (permanent establishment) can make all the difference between smooth operations and unexpected tax liabilities . Many overseas platforms offering services or digital products in Indonesia now fall under the same fiscal obligations as local entities, making classification more important than ever. The Directorate General of Taxes continues to tighten oversight to ensure fair contribution across both domestic and foreign players.

As global e-commerce and digital services grow, tax authorities are taking a closer look at cross-border revenue flows. The Ministry of Finance has introduced clear criteria for digital businesses—whether through online advertising, app stores, or subscription models—to determine when they are deemed to have a taxable presence . Misunderstanding these definitions can lead to double taxation, compliance risks, or even penalties, especially for foreign firms operating without a registered local entity.

To stay compliant, companies must evaluate their digital footprints and transaction thresholds. Insights from DDTC News show that proactive mapping of business models and reporting channels can prevent disputes while aligning with Indonesia’s new digital tax standards .

Understanding the difference between PU PMSE and BUT isn’t just about technical tax terms—it’s about protecting your brand’s credibility, keeping investor confidence high, and securing your long-term growth in one of Southeast Asia’s most dynamic markets.

Understanding PU PMSE and BUT Status in Indonesia

Indonesia’s digital economy is booming —from e-commerce to online streaming—and so are the tax rules that govern it. To operate smoothly, every foreign company must understand if it qualifies as PU PMSE or BUT.

A PU PMSE (Foreign Taxable Entrepreneur in Electronic Transactions) is typically an overseas digital business selling services or products to Indonesian users. Think of platforms like Netflix or Spotify that collect revenue locally but don’t have a physical office here.

Meanwhile, a BUT (Permanent Establishment) applies when a company has a more concrete presence—like an office, employees, or local agents. Knowing which category your business falls into helps you avoid unexpected tax issues and stay compliant with Indonesia’s digital tax system .

Understanding these terms isn’t just for accountants—it’s for every startup founder, app developer, and digital entrepreneur eyeing growth in Indonesia .

PU PMSE vs BUT Indonesia 2025 – VAT on digital services, permanent presence tests and tax reporting
At first glance,
PU PMSE and BUT might sound similar, but they serve very different tax purposes.

✅ A PU PMSE is focused on digital activities, often managed entirely online. Companies in this group must collect and remit VAT (PPN) on transactions with Indonesian consumers, even without a local branch.

 A BUT, on the other hand, implies a permanent business presence. This could mean a branch office, warehouse, or local representatives actively generating income. These businesses are subject to corporate income tax and additional reporting duties.

The Ministry of Finance created this distinction to ensure fairness—so that both local and foreign businesses contribute equally. For digital platforms, getting the classification wrong can result in penalties or double taxation later .

To be recognized as a PU PMSE, a foreign digital company must meet specific thresholds set by the Directorate General of Taxes (DGT). These include revenue generated from Indonesian users and the number of active digital transactions .

For example, companies offering online advertising, app downloads, or subscription-based content to Indonesian customers are automatically under the PU PMSE radar.

What’s key here? Transparency. Businesses must register for VAT collection once they hit the DGT threshold. Failure to do so can trigger audits or even suspension from operating in Indonesia.

By aligning with local tax rules, foreign companies show responsibility and reliability—building stronger reputations with users and regulators alike .

So, when does a foreign company become a BUT instead of a PU PMSE?

A company is considered a BUT if it has a fixed place of business in Indonesia—like an office, factory, or branch—or even if it operates through local representatives with authority to act on its behalf.

This status means the company must pay corporate income tax and report all Indonesia-based earnings. The Ministry of Finance also recognizes virtual or digital presence under certain conditions, such as sustained online operations targeting Indonesian markets.

Foreign firms should evaluate their digital footprints carefully. Even without physical offices, continuous online activity or hiring local staff may trigger BUT classification. Understanding this helps avoid unnecessary tax burdens or compliance risks .

By 2025, Indonesia’s tax landscape will be more digital than ever. Both PU PMSE and BUT entities will need to meet stricter reporting standards.

For PU PMSEs, the focus remains on VAT (PPN) collection—currently set at 11%, though it may vary based on the digital product or service. Reports are submitted monthly through the DGT’s online system.

For BUT entities, the obligation expands to corporate income tax, withholding tax, and annual filings. The key is to integrate with Indonesia’s digital systems like Coretax for seamless compliance.

Both models emphasize fairness: digital players, whether local or foreign, contribute to Indonesia’s economy equally. Staying up to date with tax changes ensures your business remains trusted and future-ready .

Indonesia digital tax enforcement 2025 – PU PMSE VAT, DTA relief and data-driven complianceThe Directorate General of Taxes (DGT) uses advanced data analytics and cross-border agreements to track digital transactions more efficiently than ever before.

Through its system, the DGT identifies platforms that generate income from Indonesian users—even if the company is based overseas. It matches digital footprints, ad revenue, and user payments .

This transparency protects Indonesia’s tax base and ensures that big global platforms and local businesses are treated equally. For companies, this means no hiding behind “digital distance.”

Businesses should ensure they report revenues accurately, pay applicable taxes, and store transaction data properly. Trust between taxpayers and authorities is built on visibility and honesty .

Double taxation happens when two countries tax the same income. To prevent this, Indonesia has Double Taxation Agreements (DTAs) with many nations .

Foreign companies classified as PU PMSE or BUT can refer to these treaties to reduce tax burdens or claim credits for taxes paid abroad. The Ministry of Finance (MoF) ensures these treaties are applied fairly, balancing investor protection and state revenue.

To stay compliant, digital businesses should:
🔹 Keep clear transaction records.
🔹 Understand local reporting cycles.
🔹 Seek professional tax consultation if unsure.

By following MoF guidelines and aligning with DGT updates, companies can safeguard their operations from financial surprises and legal risks .

Meet Daniel Fischer, a software entrepreneur from Germany who runs a mobile fitness app called FitTrack Global.

In 2023, his app gained 200,000 users in Indonesia. Though he had no office here, the Directorate General of Taxes notified him that his platform qualified as a PU PMSE. Daniel panicked—but instead of ignoring the notice, he hired a local tax consultant in Bali.

Together, they reviewed his digital revenue and user data. By registering under the PU PMSE system and collecting VAT, Daniel avoided penalties and improved his brand’s credibility. Users appreciated seeing transparent local tax info on his invoices .

Soon after, his compliance made FitTrack eligible for partnerships with Indonesian companies and online marketplaces. His story highlights how proactive compliance can lead to greater trust and long-term growth.

Transparency, adaptability, and local understanding—those are the real pillars of success in Indonesia’s digital tax ecosystem .

It stands for “Foreign Taxable Entrepreneur in Electronic Transactions,” referring to foreign digital businesses that sell services or products online to Indonesian users.

PU PMSE relates to digital transactions, while BUT applies to companies with a physical or permanent business presence in Indonesia.

The Directorate General of Taxes under the Ministry of Finance oversees digital and cross-border taxation.

Yes, if they meet the transaction threshold set by the DGT for PU PMSE classification.

By checking if their home country has a Double Taxation Agreement (DTA) with Indonesia.

Need help with PU PMSE or BUT tax in Indonesia?  Chat with our experts now on WhatsApp! 

Karina

A Journalistic Communication graduate from the University of Indonesia, she loves turning complex tax topics into clear, engaging stories for readers.