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View all search resultsPromising ‘no new tax amnesty’ is not enough
The anxiety over Indonesia's tax amnesty is that the policy created a kind of legal catch-22: In its aim to close a past legal problem, it left the legal consequences open-ended, potentially creating a new legal past for the state.
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Finance Minister Purbaya Yudhi Sadewa pauses during an interview with Reuters in Jakarta on March 3, 2026. (Reuters/Willy Kurniawan)
F
inance Minister Purbaya Yudhi Sadewa’s assurance that participants in previous tax amnesty programs would not be pursued again should be welcomed. It was a necessary reassurance, yet the episode revealed something more peculiar than ordinary public unease.
The anxiety was not only that taxpayers who accepted the state’s offer of settlement might be examined again later. It was also that officials who had administered that settlement could be questioned later over whether they had implemented it lawfully, properly and without abuse.
That unease matters, because it was cited as one reason for avoiding another tax amnesty altogether.
Can the state ask citizens and officials to rely on a policy today while leaving the legal meaning of that reliance unsettled for tomorrow? A tax amnesty is meant to close a past legal problem. But if its legal consequences are not fully closed, the policy may create a new legal past for the state itself.
Indonesia’s tax amnesty failed to reassure, not because it lacked protection but because protection is not the same as closure. Law No. 11/2016 gave safeguards to taxpayers and officials, but those safeguards operated more as conditional shields than as a complete exit architecture.
The problem was not that the law had no exit provisions but that those provisions did not make closure self-evident. The state offered closure, but parts of the past remained legally available.
Law No. 11/2016 invoked legal certainty as a guiding principle and protected participants once the relevant certificate was issued. It also restricted the use of amnesty data for criminal investigations or prosecutions and protected officials acting in good faith and in accordance with the law.
