PMK 37/2025: Key Points Online Sellers and Marketplaces Need to Understand
- Salsabila Mutiara
- 4 days ago
- 4 min read
Effective July 1, 2026, the provisions on the collection of Article 22 Income Tax on transactions conducted through officially appointed marketplaces have been implemented. Under Minister of Finance Regulation No. 37 of 2025 (“PMK 37/2025”), the government appoints certain Electronic System Trading (Perdagangan Melalui Sistem Elektronik or “PMSE”) operators as collectors of Article 22 Income Tax on income received or earned by domestic sellers through the PMSE mechanism.
The most fundamental point to understand is that this provision does not introduce a new type of tax. Income from business activities, whether generated through offline stores or marketplaces, has always been subject to Income Tax. PMK 37/2025 only changes the mechanism for settling the tax, from being calculated, remitted, and reported directly by the seller, to being collected in advance by the appointed marketplace. In addition, this regulation was introduced to create a more equal level playing field between offline and online sellers.
What Has Changed?
Following the implementation of PMK 37/2025, appointed marketplaces are now required to collect, remit, and report Article 22 Income Tax on income received or earned by domestic sellers through PMSE. Article 22 Income Tax becomes payable when the payment is received by the marketplace.
However, this does not mean that sellers are subject to an additional tax or are required to pay tax twice. The Article 22 Income Tax collected by the marketplace constitutes an advance tax payment. The amount collected will later be credited in fulfilling the seller’s Income Tax obligations, in accordance with the applicable tax regime for each seller.
Marketplaces Appointed as Tax Collectors
The parties that may be appointed as tax collectors are PMSE operators that meet certain criteria, whether domiciled in Indonesia or outside Indonesia.
These criteria include, among others, the use of an escrow account to hold sellers’ income, as well as the fulfillment of certain thresholds relating to transaction value or the number of users/accessors within a 12-month period.
Based on PER-15/PJ/2025, these thresholds include transaction value in Indonesia exceeding IDR 600 million within 12 months or IDR 50 million within one month, and/or traffic or accessors in Indonesia exceeding 12,000 within 12 months or 1,000 within one month.
At the initial stage of implementation as of July 1, 2026, the Directorate General of Taxes appointed four marketplaces as Article 22 Income Tax collectors, namely Tokopedia, Shopee, Lazada, and Blibli.
Amount of Article 22 Income Tax Collected
The Article 22 Income Tax collected by marketplaces is 0.5% of gross turnover, excluding Value Added Tax (“VAT”) and Sales Tax on Luxury Goods. The tax base refers to the transaction value stated in the billing document or invoice issued by the marketplace.
Nevertheless, the Article 22 Income Tax collected should not be viewed as a separate additional tax burden. For sellers subject to Income Tax under the general mechanism, the amount collected may be credited as a tax credit.
Meanwhile, for sellers applying a final Income Tax regime, the collected amount forms part of the settlement of final Income Tax in accordance with the prevailing provisions. If there remains an underpayment between the final Income Tax payable and the Article 22 Income Tax collected by the marketplace, the seller is still required to pay the remaining shortfall directly, as stipulated under Article 8 of PMK 37/2025.
Small Sellers Are Not Automatically Subject to Collection
Domestic individual sellers with gross turnover of up to IDR 500 million in the current tax year are not subject to Article 22 Income Tax collection by the marketplace. However, the seller must submit a statement to the marketplace confirming that their turnover is less than or equal to IDR 500 million. This statement must also be submitted together with the seller’s Taxpayer Identification Number (“NPWP”) or National Identity Number (“NIK”), as well as their correspondence address.
It should be noted that the IDR 500 million threshold is not calculated per store, per account, or per marketplace. Instead, it is calculated based on the seller’s total gross turnover in current tax year, including any sales generated outside the marketplace, whether online or offline, as provided under Article 58 paragraph (1) of Government Regulation No. 20 of 2026.
Transactions Not Collected by Marketplaces
In addition to the conditions explained above, certain transactions are not subject to Article 22 Income Tax collection by marketplace. Based on Article 10 of PMK 37/2025, these include, among others:
sales made by sellers holding a Tax Exemption Letter (Surat Keterangan Bebas or “SKB”), provided that the SKB, NPWP or NIK, and correspondence address are submitted;
sales of prepaid phone credit and SIM card;
certain transactions involving gold and jewelry;
transfers of rights over land and/or buildings; and
sales of delivery or expedition services by domestic individual partners of technology-based application companies.
However, the fact that a transaction is not collected by the marketplace does not necessarily mean that the income is not taxable. In many cases, the income remains subject to the applicable Income Tax provisions, depending on the type of transaction and the taxpayer status of the seller.
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