Updated: 26 October 2026. General guidance for foreign investors; confirm obligations against your company’s registrations and transactions.
You have established a PT PMA in Lombok, opened a bank account and started planning. Perhaps you are still looking for land, waiting for licences or building villas. There are no customers yet, so surely accounting and reporting can wait?
Usually, they cannot. A PT PMA with no revenue can still have accounting, tax, investment-reporting and corporate obligations. The key distinction is between having no taxable profit and having no reporting requirement. These are separate questions.
Your company may owe no ordinary corporate income tax on its trading results while still needing to file an annual return, account for shareholder funding and report investment progress. Payments to employees, landlords or contractors can also create obligations before your first sale. [1–4]
First, what does “inactive” actually mean?
A pre-revenue company
This company is preparing to trade. A restaurant undergoing fit-out in Kuta Lombok or a tourism operator purchasing equipment is undertaking business activity, even without sales. Preparation can involve substantial expenditure, assets and liabilities.
A temporarily inactive company
Operations have paused, but the owners intend to resume. For example, a villa project might stop while financing is renegotiated. The company still exists, and its reporting position does not automatically change because work has stopped.
A “dormant” company
Owners often use “dormant PT PMA Indonesia” to describe a company doing little or nothing. That description alone does not establish an exemption.
Formal Wajib Pajak Nonaktif, or nonactive taxpayer status, is different. Corporate eligibility is governed by tax rules and requires a DJP determination. Under PMK 81/2024, corporate criteria include no longer meeting subjective and objective taxpayer requirements while NPWP deletion remains pending, or other criteria prescribed by DJP. Simply having no sales is insufficient grounds to assume eligibility. [2]
DJP explains that nonactive taxpayers are relieved of SPT filing from the tax year of designation. Confirm the effective period and outstanding earlier obligations. This tax status does not itself dissolve the company or cancel OSS and investment-reporting responsibilities. [3]
A company that should be closed
If the project has been abandoned permanently, compare ongoing maintenance costs with formal closure. Dissolution and liquidation involve company-law procedures, settling assets and liabilities, and relevant administrative closures. Stopping bank activity or abandoning filings is not liquidation. [8]
Your pre-revenue compliance checklist
| Area | What may still be required | Practical action |
|---|---|---|
| Accounting | Books and supporting records despite no sales | Record funding, spending, assets and liabilities |
| Annual corporate tax | Annual SPT unless a valid exception applies | Prepare accounts and check taxpayer status |
| Monthly taxes | Transaction-specific withholding and applicable VAT returns | Review payments and registrations monthly |
| LKPM | Investment-progress reporting before commercial operation | Report the correct project stage and actual figures |
| OSS and licences | Accurate data and applicable approvals | Track outstanding requirements and changes |
| Company administration | Registers, resolutions and annual reporting | Maintain a corporate calendar |
| Employees | Payroll, tax and employment benefits | Budget compliance from the hiring date |
Bookkeeping starts before the first customer
Indonesian corporate taxpayers generally must maintain books. Supporting books, records and documents must generally be retained for 10 years in Indonesia, at the corporate taxpayer’s domicile. [1]
For a new Lombok business, establish a monthly folder containing:
- Company bank statements and reconciliations.
- Supplier invoices, contracts and payment receipts.
- Shareholder funding agreements and transfer confirmations.
- Deposits, equipment purchases and construction records.
- Payroll, tax documents and filing acknowledgements.
Do not record every outgoing payment as an immediate expense. A refundable property deposit, prepaid lease, kitchen equipment and villa construction costs may require different accounting treatment. Your accountant should distinguish expenses from assets, advances and construction in progress, then assess their tax treatment.
Even an otherwise empty company bank account can generate charges or interest. Reconcile the statement rather than assuming “no sales” means every figure is zero.
Annual corporate tax returns: no income does not mean no return
For an ordinary active corporate taxpayer, a PT PMA tax return with no income is still generally required. Financial statements and tax calculations establish the position; an empty sales ledger does not replace them. [4]
The normal annual corporate SPT deadline is four months after the tax year ends—normally 30 April for a calendar-year company. Confirm any applicable extension or official relief rather than assuming it exists. [5]
No sales may produce an accounting loss, but an accounting loss and a tax loss are not necessarily identical. Some expenditure belongs on the balance sheet, and tax adjustments may apply. Bank interest or other income also needs review.
Monthly tax obligations depend on what actually happens
Avoid both extremes: assuming no monthly obligations exist, or assuming every possible nil return must always be filed.
Relevant questions include:
- Have employees or directors been paid?
- Has the company paid rent, consultants, contractors or overseas suppliers?
- Is it registered as a VAT taxable entrepreneur, or PKP?
- Has it imported equipment or made transactions with specific tax treatment?
Payroll and supplier payments can trigger withholding obligations even without revenue. PKP businesses generally must submit monthly VAT returns even when there are no transactions. Nil-return rules differ by tax type, so have the accountant document which returns apply and why. [6]
A dive business importing equipment before opening should also retain customs declarations, invoices and tax-payment documents. Import-related taxes and the treatment of input VAT or tax credits need separate assessment; absence of sales does not settle those questions.
Use a current filing calendar. Coretax reporting rules have changed, including amendments issued in September 2026, so an old incorporation checklist may be inadequate. [6]
LKPM reports investment progress, not just revenue
LKPM with no revenue is entirely possible: preparation and construction are part of investment implementation.
Under Investment/BKPM Regulation 5/2025, medium and large businesses generally report quarterly, including through a preparation-stage LKPM before commercial operations. PT PMAs generally fall within the large-business framework. Reports are organised by business activity and location after issuance of the NIB. [7]
The regular deadlines are 15 April, 15 July, 15 October and 15 January of the following year, subject to officially announced adjustments. Check the current OSS notice for each period. [7]
Report actual investment, employment, progress and obstacles. If a Lombok villa project is awaiting approval, explain that status. If no additional investment occurred, report the facts; do not invent expenditure or omit construction payments merely because revenue is zero.
Reconcile investment figures with accounting records. Funds entering the bank and funds spent on the project are different events: do not automatically count both as separate realised investment.
Keep OSS, licences and company records current
Indonesia’s current risk-based licensing framework is governed by Government Regulation 28/2025, which replaced Regulation 5/2021. An NIB does not automatically satisfy every approval needed for construction or operations. [9]
Check the company’s KBLI activities, project location, applicable standard certificates or licences, and relevant spatial, environmental and building requirements. A tourism business awaiting licences should track outstanding requirements rather than treating the delay as a compliance holiday.
For Lombok projects, consult the DPMPTSP responsible for the actual location. A restaurant, accommodation business and marine tourism operation can have different requirements.
Maintain shareholder registers, meeting records, funding approvals and changes to directors or addresses. Company law generally requires an annual report and annual shareholders’ meeting within six months after financial year-end. These are separate from the corporate tax return. [8]
After changes, verify records across AHU, OSS, tax administration and the bank; do not assume every system updates automatically.
Employees create obligations before opening day
Hiring a villa manager or restaurant team before opening means budgeting for more than wages. Review employment agreements, applicable payroll withholding, BPJS Kesehatan and BPJS Ketenagakerjaan registration and contributions, working-time requirements and THR eligibility. [10]
Keep attendance, payroll calculations and payment evidence. Delayed opening does not automatically suspend employment rights. If funding runs out, obtain advice before reducing pay or ending employment.
Common mistakes—and a manageable routine
The biggest mistake is waiting until sales begin to appoint an accountant. By then, reconstructing months of personal payments and missing invoices can be expensive.
Other avoidable problems include undocumented shareholder loans, missed LKPM submissions, outdated licences and assuming a “dormant” company needs no annual return.
A practical routine is to:
- Reconcile the bank and classify transactions monthly.
- Review payroll and payment-related taxes before paying suppliers.
- Maintain a quarterly LKPM reminder and save submission evidence.
- Schedule annual tax and corporate obligations separately.
- Review whether the business should continue, seek an eligible formal status change, or close.
For PT PMA compliance in Indonesia, ask advisers for a written scope covering accounting, tax, LKPM and corporate administration. These services are not automatically included in one another.
FAQ
Can I stop reporting if the company has no bank transactions?
Not automatically. Check tax status, annual filing requirements and investment obligations separately.
Is LKPM replaced by the annual tax return?
No. They serve different purposes and go to different administrative systems.
Can an inactive company in Indonesia apply for nonactive tax status?
Possibly, if it meets the corporate criteria. Obtain a formal determination; do not self-declare an exemption.
Should I keep a PT PMA that I will never use?
Compare ongoing compliance costs with formal closure. Ask a tax adviser and notary to assess outstanding liabilities and the closure process first.
Sources and Further Reading
Official sources checked on 26 October 2026. Regulations should be read together with their applicable amendments.
- DJP — Government Regulation 50/2022: tax rights, obligations and record retention.
- DJP — PMK 81/2024, particularly Article 45 on corporate nonactive taxpayer status, and PMK 1/2026, its fourth amendment.
- DJP Coretaxpedia — Applying for nonactive status and its filing implications.
- DJP — No business activity: must you still submit a tax return?. This older explanation uses the former terminology; consult sources 2–3 for current status terminology.
- DJP — Tax-return filing deadlines and current annual Coretax filing guidance.
- DJP — PER-11/PJ/2025 reporting rules, PER-12/PJ/2026 amendment, and DJP explanation of nil VAT returns.
- Ministry of Investment/BKPM — Regulation 5/2025, particularly Articles 285–286 on LKPM.
- Ministry of Finance legal database — Company Law 40/2007, as amended; see annual reporting, company records and liquidation provisions.
- BPK legal database — Government Regulation 28/2025 on risk-based business licensing.
- BPJS Ketenagakerjaan — Wage-earner membership, Ministry of Manpower — Government Regulation 35/2021, and State Secretariat — 2026 THR guidance.