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Dissecting Facilities at PFII: From 100% Corporate Income Tax Reduction to Golden Visa

November 13, 2026

Law Number 6 of 2026 concerning the Indonesian International Financial Center (PFII Law), which takes effect from August 19, 2026, prepares a package of facilities with a wide scope. These facilities not only target companies, but also experts, foreign investors, and high-net-worth individuals. Chapter VIII of the PFII Law regulates these facilities in detail, and here is a summary point by point.

Who can receive the facility?

Based on Article 47 of the PFII Law, those who can receive facilities are divided into five groups, namely:

• Business actors who carry out business activities at PFII, both in the financial sector, supporting the financial sector, and other sectors;
• Financial sector experts, both foreigners and Indonesian citizens, who meet certain criteria;
• Ad hoc judges of the PFII Court who have the status of foreigners;
• Foreign tax subjects (SPLN), namely foreign persons or entities who are not domiciled or domiciled in Indonesia, who invest in PFII; and
• PFII Management Institution (LP) and Financial Services Supervisory Institution (LPJK) PFII.

Types of facilities and their duration

The PFII Law divides tax facilities into three types, namely income tax (PPh), value-added tax (VAT) and/or sales tax on luxury goods (PPnBM), as well as special customs for income tax facilities, the period is differentiated according to the type of activity:

• Core sector, namely financial and investment sector businesses by SPLN: 50 years (Article 48 paragraph (2)).
• Support for the financial sector, other sectors, as well as LP PFII and LPJK PFII: shorter than 50 years, with a duration that will be regulated in ministerial regulation (Article 48 paragraph (3)).

This period is not automatically enjoyed. Article 48 paragraph (4) of the PFII Law limits the income tax facility only to income derived from PFII and only for parties who meet certain qualifications. Thus, the income of business actors from activities outside PFII basically does not obtain this facility.

Income tax facility

Based on Article 49 of the PFII Law, it regulates five forms of income tax facilities, each with different recipients and conditions which are explained as follows:

• Income from abroad is not taxed (Article 50 of the PFII Law). Business actors and foreign financial sector experts in PFII are only subject to income tax on income sourced from Indonesia. The explanation of Article 50 refers to this scheme as a territorial income system, different from Indonesia’s general system which taxes income from all over the world (worldwide income system).
• Reduction of corporate income tax by 100% (Article 51 of the PFII Law). This facility is provided to business actors in the three groups of business activities, as well as to LP PFII and LPJK PFII for their operational activities.
• Final income tax 0% (Article 52 of the PFII Law). This facility is valid for a certain period of time on the income of experts working for financial sector business actors at PFII and ad hoc judges  of the PFII Court. The facility is calculated from the moment experts start working or judges start hearings.
• Exemption as a domestic tax subject (Article 53 of the PPII Law). Foreigners are not treated as domestic taxpayers if they meet three conditions: registered in the family office (family wealth management institution) at PFII, hold  a PPII golden visa, and do not earn income from active business or work in Indonesia. This facility is valid as long as  the golden visa is still valid.
• Exemption from withholding or collection of income tax (Article 54). SPLN is not deducted from income tax on its investment income in PFII, including interest, dividends, discounts, asset transfer profits, and branch profit tax. Exemption from income tax also applies to the purchase of very luxurious residences in PFII by parties who are active or live in PFII.

VAT and PPnBM Facilities

In the field of VAT, the PFII Law uses a VAT not collected scheme. This means that VAT is still payable but not collected, so that buyers or importers do not bear it. This facility is given to three groups of objects (Article 57):

• Strategic goods, namely new buildings in the form of landed houses, apartment units, offices, shops or shopping centers, and warehouses for certain parties in PFII, as well as other strategic goods needed for the construction of PFII.
• Strategic services include property rental services to parties engaged in PFII activities and construction services for roads, bridges, renewable energy plants, water and telecommunication networks, hospitals, schools, offices, and similar infrastructure.
• Import of capital goods needed for the construction and development of PFII.

Other facilities

In addition to Taxation, the PFII Law stipulates other facilities that can be applied for the PFII Area, namely the exemption of incoming rice for entrepreneurs in the PFII Area for  import transactions of goods for the development and development of PFII.

Special treatment

The PFII Law also stipulates other special treatment that can be applied to the PFII Area, namely:

• Inheritance. Inheritance taxes are not levied at PFII as long as the inherited property and its heirs, who are foreigners, are both registered in the PFII family office.
• Initial capital of LP PFII. Property grants for the initial capital of LP PFII are subject to 0% final income tax, both for the grantor and LP PFII as the recipient. The basis for its imposition is the fiscal book value of the grantor

Special non-tax facilities

In addition to tax facilities, the PFII Law provides special non-tax facilities for business actors, experts, and other parties in PFII (Article 65 paragraph (1)), in the form of facilities in the following fields:

• Immigration, residence permits, and residency;
• Employment and licensing; and
• Golden Visa and other facilities.

Among these facilities, the golden visa received the most detailed explanation. Article 65 explanation states that this facility is intended to attract investment and make Indonesia a second home for ultra High Net Worth Individuals from abroad, with qualifications including investment value, certain skills, and registration in the PPII family office.

Conclusion

The PFII Law offers facilities that reach almost all parties in the Region, ranging from a 100% reduction in corporate income tax with a period of up to 50 years for the core sector, territorial taxation, 0% final income tax for experts, exemption from withholding income tax for foreign investors, VAT facilities, PPnBM, and import duties, to golden visas.

However, these facilities do not apply automatically. Qualification requirements, global minimum tax provisions, and unpublished implementing rules will determine how much benefit can actually be enjoyed.

Andersen in Indonesia team is ready to help your company assess the feasibility of obtaining facilities at PFII, calculate the impact of the global minimum tax, and prepare  the required transfer pricing structure and documentation. Contact us to strategize the utilization of PFII facilities early.

By Tommy Hendharto Oetomo – Managing Partner