Penulis: Sutan RH Manurung (Principal Led Strategic Advisor | MD Eksakta Strategic | Chairman of ITTF AKP2I )

Jakarta - Since 1 January 2024, the global tax landscape has fundamentally changed. Through the OECD/G20 Inclusive Framework,BEPS 2.0 – Pillar Two introduced a 15% global minimum effective tax rate (ETR) for multinational groups with revenues above EUR 750 million, based on the GloBE Rules (2021).

On paper, this marks a historic shift: from tax competition → to tax coordination. 
But the reality in 2025–2026 tells a different story. 
The System (in principle) 
If ETR < 15% → Top-Up Tax applies 
If ETR ≥ 15% → No additional tax

(Simple in theory. Complex in execution.)

Indonesia’s Position

Indonesia has aligned with this global framework through:

– PMK No. 136 Tahun 2024 
– Adoption of OECD GloBE Model Rules and Administrative Guidance

This reflects a significant shift in Indonesia’s international tax architecture.

What we are actually seeing not full harmonization. But what I would describe as “Coordinated Fragmentation”. Jurisdictions are implementing the same framework — with different interpretations, priorities, and fiscal interests.

The implications are immediate:

* Overlapping taxing rights 
* Increasing complexity in ETR calculations 
* Diverging rule interpretations 
* Rising cross-border tax disputes

Baca Juga: https://akp2i.or.id/berita/wajib-pajak-menerima-bukti-potong-dari-perusahaan-yang-tidak-dikenal-di-coretax-langkah-teknis-risiko-kepatuhan-dan-perspektif-kebijakan-publik

A Structural Shift

Global tax competition has not disappeared. It has evolved.

From: 
– Rate competition to Rule-based competition

From: 
– Tax planning to Tax controversy management

From: 
– Compliance to Strategic positioning

The Question: Are we moving toward a fairer global tax system?or Are we simply redistributing taxing rights within a more complex architecture?