JAKARTA - The government has issued two Regulations of the Minister of Finance (PMK) which regulates tax provisions for Bulion business activities.
Adapun, PMK tersebut adalah PMK Nomor 51 Tahun 2025 dan PMK Nomor 52 Tahun 2025. Kedua PMK tersebut ditetapkan pada tanggal 25 Juli 2025 dan mulai berlaku efektif pada tanggal 1 Agustus 2025.
The issuance of the two PMKs aims to simplify regulations and provide legal certainty.
The background of the preparation of the two PMKs is that there is a need for support for Bulion business activities in the form of adjusting tax arrangements with the development of Bulion business activities which have been regulated in Law Number 4 of 2023 concerning the Development and Strengthening of the Financial Sector (P2SK).
In addition, the Bulion business includes activities related to gold, such as deposits, financing, trade, and gold storage by financial service institutions.
Previously, the provisions for collecting PPh Article 22 on Bulion business activities had been regulated in PMK 48 of 2023 and PMK 81 of 2024, which caused overlap. For example, gold sellers collected Article 22 of PPh of 0.25 percent for sales to the Financial Services Institution (LJK) Bulion, while LJK Bulion as a buyer also collected Article 22 PPh of 1.5 percent for the same purchase, "said Director of Counseling, Services, and Public Relations, Rosmauli, Thursday, July 31.
He added that this new provision is expected to eliminate the potential for overlap.
The first PMK is PMK Number 51 of 2025 concerning Article 22 Income Tax Levy in connection with Payments for the Delivery of Goods and Activities in the Import or Business Activities in Other Fields (PMK-51/2025).
The new regulatory principal in PMK-51/2025 includes the appointment of LJK Bulion as a collection of PPh Article 22 for the purchase of gold bullion, as well as the determination of Article 22 of PPh on gold bullion imports of 0.25 percent.
This PMK also regulates that the final sale of gold by consumers to LJK Bulion is up to Rp10,000,000, except from the collection of Article 22.
The second PMK is PMK Number 52 of 2025 concerning the Second Amendment to PMK Number 48 of 2023 concerning PPh and/or VAT on Sales/Submission of Gold Jewelry, Gold Batangan, Jewelry with All Materials Not from Gold, Stone Permata and/or Other Similar Stones, as well as Services Related to Gold Jewelry, Gold Batangan, Jewelry with All Materials Not from Gold, and/or Rock Permata and/or Other Similar Stones, carried out by Gold Jewelry Manufacturers, Gold Jewelry Traders, and/or Barangan Gold Entrepreneurs (PMK-52/2025).
PMK-52/2025 regulates the provisions of Article 22 of PPh for Bulion business activities in the form of trading bullion.
In addition, the PMK also stipulates that the collection of PPh Article 22 is not carried out on the sale of gold jewelery or gold bullion by gold jewelery entrepreneurs and/or gold bullion to final consumers, MSME taxpayers with final income tax, and taxpayers who have a PPh 22 Free Certificate (SKB).
Similar exceptions also apply to the sale of gold bullion to Bank Indonesia, through the physical digital gold market, and to LJK Bulion.
The provisions in the two PMKs explain that the purchase of gold bullion by the public (final consumer) from Bank Bulion is not subject to the collection of Article 22.
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Sales of gold to LJK Bulion are also excluded from collecting PPh Article 22 if the transaction value does not exceed Rp. 10,000,000. However, if the transaction value is more than Rp. 10,000,000, LJK Bulion must collect Article 22 PPh of 0.25 percent of the purchase price.
"The provisions for collecting PPh Article 22 on Bulion businesses are not a new type of tax, but a form of adjustment so that there is no overlap in the imposition of taxes," he explained.
He also emphasized that the DGT will continue to adjust tax regulations according to the dynamics of the financial decree, including business activities of Bulions and gold bullion.
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