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Andi Refandi
Andi serves as a Senior Account Executive on Emerhub’s global team.
Indonesia Tax Authority distributes SP2DK to both Resident Tax Payer and Corporate Tax Payer. An SP2DK is not a tax assessment or a fine. It is a formal request for clarification.
If you’ve received an SP2DK letter from the Directorate General of Taxation (DJP), it means that they found discrepancies between what you reported in your annual tax return and data they obtained from other sources.
Your response to this letter will determine the outcome: the case could be closed with zero issues, or it could escalate into a full-scale tax audit.
What is SP2DK and Why Did You Receive It?
SP2DK stands for Surat Permintaan Penjelasan atas Data dan/atau Keterangan (Clarification Request Letter for Data and/or Information). It’s an official letter from your local tax office requesting that you explain specific discrepancies between your reported assets or income and information they obtained from other sources.
DJP uses SP2DK as an efficient verification tool, particularly toward the end of the fiscal year when Account Representatives need to meet collection targets.
Rather than immediately launching formal audits, they first ask taxpayers to clarify potential issues. This gives you the opportunity to explain legitimate reasons for discrepancies before any enforcement action.
Why Did You Receive SP2DK Letter?
The tax office sends these letters when their data matching system flags an inconsistency.
For example, a client has paid you Rp. 25,000,000 for services rendered. This payment is recorded by the tax authorities through a withholding tax of 2% on the Rp. 25,000,000, linked directly to your name.
However, in your tax returns, you only reported an income of Rp. 10,000,000.
The significant discrepancy between the validated client payment and your reported income raises a red flag for the tax authorities.
In this case, they will issue an SP2DK to request clarification on why there is a mismatch, suspecting potential underreporting of income.
How Does the Tax Authority Find These Discrepancies?
In the past, tax reporting relied heavily on honesty. Today, the DJP uses Automatic Exchange of Information (AEOI) and domestic data integration to see your financial footprint clearly.
Where they get their data:
- Foreign Banks: If you hold accounts in Singapore, Hong Kong, or Australia, those banks report your balances to Indonesian authorities annually under AEOI protocols.
- Domestic Institutions: Local banks, insurance companies, and securities brokers automatically report your transaction data.
- Asset Registries: Property purchases, vehicle registrations, and shareholdings are cross-referenced against your reported income.
Here is the most common trigger for an SP2DK:
| Asset Type | What You Reported (SPT) | What DJP Found (Data) | Result |
| Bank Accounts | Bank ABC (Jakarta): Rp 70M | Bank ABC: Rp 70M Bank XYZ (Singapore): SGD 50k | SP2DK Issued |
The tax office simply wants to know: Where did the money for the Singapore account come from, and has it been taxed?
How to Respond Tax Office Notice (SP2DK)
Your response to SP2DK determines whether this matter closes quickly or escalates into something more serious. The deadline for responding is typically stated in the letter (usually 14 days from receipt).
Please be advised that you should not ignore the SP2DK. That is the worst possible response. The tax authority has already documented the discrepancy. Failing to respond moves your case directly toward formal audit. In that case, you’ll face much more intensive scrutiny, potential penalties, and significantly higher professional fees to handle.
1. Read the Letter Carefully
The SP2DK will be specific and will list exactly which tax year and which assets are in question. Some of the common flags include:
- Unreported bank accounts.
- Property purchases that exceed reported income.
- Business ownerships not declared in your SPT.
If you are not sure what your next steps should be, it is strongly recommended to assign a Tax Consultant such as Emerhub to represent you.
Our consultants will review the letter, help you understand its contents, and explain the specific requirements and implications. Understanding precisely what the authorities are questioning is crucial for setting the stage for an accurate and timely response.
2. Gathering and Verifying Information
You must prove the source of funds for the assets in question. DJP accepts the following as valid proof:
- Inheritance: Inheritance deeds or Akta Waris.
- Already Taxed Income: Withholding tax slips (Bukti Potong) from the relevant years.
- Loans: Loan agreements if the asset was purchased using debt.
- Non-Taxable Income: Grants or gifts from direct blood relatives (requires specific documentation).
We will help you cross-check the data against your records to ensure accuracy and identify any mistakes.
3. Submitting the Clarification Response
Once all the documents are ready, the next step is to draft a comprehensive and accurate response letter. Keep in mind that if your explanation is legally weak or your documents are disorganized, the authorities will reject them.
When you are working with us, we will handle the preparation and submission of your response and handle communication with the tax office on your behalf.
The entire process normally takes six to eight weeks from receiving SP2DK to final outcome. Most time is spent on the tax authority’s internal review after you submit your response.
What Happens After You Respond to SP2DK?
Once you submit your clarification and supporting documents, the Account Representative analyzes your response and prepares an internal report called LHP2DK (Laporan Hasil Pengawasan dan Pemeriksaan Data dan/atau Keterangan).
Kindly note that the LHP2DK is an internal document you will never receive.
It’s DJP’s assessment of your explanation, comparing your documentation against their data sources and determining what action to take next.
Based on the LHP2DK analysis, DJP will take one of these actions:
| Your Situation | LHP2DK Conclusion | What Happens Next |
| Your explanation is satisfactory with complete documentation | No tax compliance issues found | SP3P2DK issued (case closed, no further action) |
| You didn’t respond to SP2DK | No explanation provided | Escalation to formal tax audit |
| Your explanation doesn’t match their data or documentation is insufficient | Evidence suggests unpaid tax | Escalation to formal tax audit |
| You acknowledge the discrepancy and agree to correct your tax return | Willing to voluntarily correct SPT | Supervision of SPT correction (you amend your return and pay any tax due, avoiding audit) |
| Evidence suggests intentional tax evasion or criminal activity | Suspected tax crime | Escalation to preliminary evidence examination for potential criminal prosecution |
How Emerhub Can Help with Your SP2DK Response
Responding to SP2DK requires understanding what documentation DJP accepts, how to frame your explanation, and what standards satisfy their review. Many taxpayers with legitimate asset sources still face audits because their responses didn’t meet DJP’s documentation expectations.
Our local experts handle the entire process on your behalf:
- Strategy: We analyze the discrepancy to see if it is a reporting error or a tax liability.
- Documentation: We organize your proofs (bank slips, deeds, agreements) into a compliance dossier.
- Representation: We speak to the Account Representative on your behalf, ensuring no miscommunications occur.
If you have received an SP2DK, send a copy to our tax team immediately. We will review the specific demands and give you a preliminary assessment of your risk level.
Frequently asked questions
No. It is a request for clarification. If you can prove the asset was bought with income you already paid tax on (or non-taxable income like inheritance), you owe nothing.
Your case automatically escalates to formal tax audit. DJP interprets non-response as either inability to explain the discrepancy or unwillingness to cooperate. Audits are more invasive, take longer, and typically result in higher penalties than voluntarily addressing issues at the SP2DK stage.
Yes, you can submit your explanation to DJP directly. However, most taxpayers engage consultants because responses need to meet specific documentation standards and format expectations. An incomplete or poorly explained response often results in rejection and may trigger an audit even when you have legitimate sources.
