Publications

The Rules for Taxpayer Proxies have Changed: Here’s What Taxpayers Need to Understand Before 2027

September 1, 2026

The rules on taxpayer proxies have changed. The government has officially enacted Minister of Finance Regulation (PMK) No. 44/2026 on July 6, 2026, revoking the old regulation, PMK 229/PMK.03/2014. Notable changes include new competency requirements and strict transition deadlines. Taxpayers, especially multinational companies or entities with complex tax structures, who are used to assigning tax consultants, employees, or other parties as their tax proxy should be prepared to meet the new requirements.

What’s changed?

Previously, only two parties could be appointed as tax proxies—tax consultants and taxpayer employees. Now there are three categories, namely:

• Tax consultants
• Other parties
• Family members

A big change is the introduction of family members as its own category, for which there are no competency requirements for husbands, wives, or relatives by blood or marriage up to the second degree. Evidence of the family relationship must be provided, such as a copy of the Family Card or a family relationship statement (Article 7, paragraphs 3-4). This is good news for individual taxpayers and small and medium businesses who may have difficulty in accessing licensed tax consultants.

The terms of appointment have also been adjusted. As stated above, if the taxpayer appoints a family member, they do not need to attach the certificate of registration (or “SKT”). Tax consultants are automatically considered competent as special attorneys. However, those in the “other party” category are required to have an SKT to prove their competence. (Further details on other parties and the procedure to obtain the SKT will be provided through a separate ministerial regulation that has yet to be issued.)

There are restrictions on who can become a tax proxy. Article 4 prohibits tax consultants or other parties who are subject to sanctions of freezing or revocation of permits or SKT. Former employees of the Ministry of Finance are also subject to stricter rules: those who have retired or quit before retirement age, and former employees with employment agreements (PPPK) are required to wait at least five years after they have stopped working, and they must never have been subject to severe disciplinary measures while serving.

New format for the special power of attorney. Given the expansion of parties eligible to be appointed as an authorized representative, the old format for a special power of attorney needed to change since it only accommodated tax consultants. The new format allows for the three categories of representatives, each with different supporting document requirements. The new format also explicitly adds a validity period for the power of attorney, an itemized breakdown of the authority granted, and a statement granting access to the taxpayer’s electronic account in the DGT’s system, in line with the rollout of the Coretax electronic tax administration system.

Transition period

PMK 44/2026 provides for a transitional phase. Special powers of attorney that were made before this rule entered into effect are still valid. Holders of brevet certificates or tax diplomas with at least a Diploma III accredited A can still be a power of attorney until December 31, 2026, as long as the power of attorney is made in paper form with a photocopy of the certificate or diploma attached.

For companies that have been using employees with brevets or diplomas as proxies, this is the time to prepare. Their status needs to be adjusted to “other parties” with an SKT before the transition deadline expires, even though the technical rules regarding the SKT itself have not yet been issued. The format of the special power of attorney must also be updated because it must now explicitly state the status of the power of attorney.

Actions to take now

For taxpayers, especially multinational companies that tend to have internal proxies, these three things should be a priority to avoid tax proxies losing their authorization precisely when it is needed most:

• Map all parties that can be appointed as active proxies and their competency bases.
• Update special power of attorney documents according to the new format.
• Monitor the issuance of technical ministerial regulations on SKT.