Indonesia tetap memainkan perannya dalam konteks global dimana pada tahun 2023 Indonesia akan menjadi tuan rumah atau ketua ASEAN atau bisa juga disebut dengan presidensi ASEAN. Keketuaan Indonesia di ASEAN berlangsung mulai 1 Januari hingga 31 Desember 2023 dan menunjukkan kepercayaan kawasan terhadap Indonesia untuk mencapai pertumbuhan inklusif dan berkelanjutan di kawasan ASEAN di tengah pemulihan global pascapandemi. Indonesia sendiri melalui keketuaan ASEAN 2023 ingin menunjukkan kepemimpinannya di kawasan Asia Tenggara yang akan tetap kokoh meski melewati pandemi COVID-19 yang membuat negara-negara di kawasan tersebut goyah, termasuk Indonesia.
Di bidang perpajakan, khususnya dari segi jumlah nominal realisasi penerimaan pajak pada tahun 2022, Indonesia menjadi yang tertinggi seiring dengan Produk Domestik Bruto (PDB) yang juga terbesar di kawasan ASEAN. Namun besaran tax rasio atau perbandingan antara realisasi penerimaan pajak dengan PDB Indonesia masih lebih rendah, bahkan di bawah rata-rata daerah. Hal ini akan menggambarkan penerimaan pajak Indonesia yang tidak sebanding dengan besarnya PDB Indonesia dibandingkan negara lain. Lebih lanjut, perlu dilakukan pendalaman perbandingan struktur perpajakan antara Indonesia dan negara-negara ASEAN untuk mengetahui sektor mana yang sudah cukup baik dan mana yang mungkin perlu ditingkatkan.
Perbandingan Tax Ratio , Total Penerimaan Pajak dan Cukai, Realisasi PPN Tahun 2022 Antar Negara ASEAN (Dalam Triliun Rupiah)
| Negara | Rasio Pajak | Jumlah Penerimaan Pajak dan Cukai | Realisasi PPN | Persentase PPN* |
| Kamboja | 18,36% | 82,17 | 26,25 | 31,94% |
| Thailand | 17,18% | 1.403,43 | 349,48 | 24,90% |
| Orang Vietnam | 16,21% | 1.006,20 | 434,60** | 43,19% |
| Singapura | 12,96% | 951,86 | 167,91 | 17,64% |
| Malaysia | 11,75% | 733,01 | 190,06 | 28,43% |
| Rata-rata | 10,75% | 692,07 | 207,92 | 29,54% |
| Filipina | 10,43% | 652,63 | 224,57** | 34,41% |
| bahasa Indonesia | 10,39% | 2.034,58 | 660,98 | 38,50% |
| Laos | 9,46% | 29,07 | 12.15** | 41,82% |
| Myanmar | 5,78% | 52,99 | 13,21 | 34,56% |
| Brunei | 1,30% | 3,89 | 0,00 | 0,00% |
* Persentase PPN dibandingkan Total Penerimaan Pajak 2022 (tidak termasuk Cukai)
** Realisasi PPN tahun 2020 dengan asumsi pertumbuhan 5% per tahun
If dissected, the structure of Indonesian taxation is mostly held by the Value Added Tax (VAT) sector, as are most ASEAN countries, some of which equate VAT with Sales and Service Tax (SST) in Malaysia or Commercial Tax in Myanmar. In comparing tax ratios among ASEAN member countries, it is also necessary to compare which tax sectors contribute the most to the realization of tax revenues such as VAT sector. In terms of nominal VAT revenue, Indonesia remains the highest in line with its order of total tax revenue as a whole compared to regional countries. But in the ratio of VAT to total receipts, Indonesia is not the first but in third place after Vietnam and Laos.
If traced further, Thailand, Malaysia, Singapore and Brunei, which incidentally are countries that have the highest per capita income in the region, are not too dependent on VAT because of the contribution of VAT. which is precisely below the regional average. This can be due to lower rates in these countries or higher income tax sizes due to higher per capita income so that the income tax exceeds VAT. But still, the four countries have a higher tax ratio than Indonesia, so Indonesia’s focus on taxation may be better directed to other sectors as well such as Personal Income Tax and Corporate Income Tax whose contribution is greater in these countries. For this reason, in comparing the VAT sector, among ASEAN member countries, it is also necessary to compare how much the tariff is among regional countries and how many VAT facilities are charged to these countries.
VAT Tax Rate Comparison Among ASEAN Countries
| Country | VAT/GST percentage | VAT/GST rates |
| Vietnamese* | 43,19% | 10% |
| Laos* | 41,82% | 7% (From 1 January 2022) |
| Indonesian | 38,50% | 10% and 11% (From April 2022) |
| Myanmar | 34.56% | Commercial tax 5% |
| Phillipines* | 34,41% | 12% |
| Cambodia | 31,94% | 10% |
| Malaysia | 28,43% | 10% (Sales) and 6% (Service) |
| Thailand | 24,90% | 7% (Until 30 Sep 2023) and 10% (Normal) |
| Singapore | 17,64% | 7% and 8% (From 1 Jan 2023) |
| Brunei | 0,00% | – |
When compared with ASEAN countries, Indonesia’s general VAT rate is the second highest after the Philippines so it is quite reasonable if the percentage of Indonesian VAT realization is higher than most ASEAN countries. This shows that with the reform, Indonesia’s VAT has been increased enough, but Indonesia still has to look in the mirror with Vietnam and Laos because Vietnam and Laos have general rates that lower but higher VAT realization percentage. Furthermore, Vietnam has a higher Tax Ratio than Indonesia even the nominal VAT of Vietnam is close to the nominal VAT of Indonesia. Instead of that, all of Vietnam can be considered quite capable of maximizing its taxation at a rate of 10%, although the VAT facility between Indonesia and Vietnam needs to be compared further.
Then it was also seen that indeed the four countries whose VAT realization ratio was below the ASEAN average because the applicable tariffs in these countries were relatively low compared to Indonesia or even relatively low in the ASEAN region except compared to Myanmar. Malaysia’s sales tax rate is fairly normal at 10% but the service tax rate is only 6% at a time when the service sector itself is the largest contributor to Malaysia’s GDP, Malaysia is trying to minimize tariffs on its largest sector. Thailand in [1] previous years had a reasonable VAT rate of 10%, but due to the pandemic, Thailand lowered the VAT rate to 7% until September 30, 2023 in order to recover the economy. Singapore has the lowest rate of 7% while Brunei does not apply VAT or equivalent like Malaysia with SST and Myanmar with Commercial Tax. This shows that in these four countries, there may be a government mindset that prioritizes economic recovery by minimizing VAT rather than the idea of prioritizing state income by increasing VAT as brought by Indonesia.
Supported by the differences between Indonesia and several ASEAN countries in adjusting VAT rates where countries such as Thailand and Laos which precisely due to covid lowered their VAT rates, on the contrary with Indonesia is increasing its tariffs. Singapore has also actually started to increase its tariffs although it remains at a low level, but it will only take effect on January 1, 2023 or at least its economy has recovered in contrast to Indonesia which implements tariff increases in times of economic recovery. With the exception of Laos, the difference in this action is also based on the fact that VAT in Thailand and Singapore is not the largest contributor to the realization of tax revenues of these countries, in contrast to Indonesia where VAT is the biggest contributor.
VAT Facility among ASEAN Countries
| Country | Exempt / 0% VAT/GST rate | Special Rates |
| Vietnamese | 0% for Export of Goods and Services, VAT exemption for some agricultural products, import/lease of aircraft, drilling rigs, ships, various financial services, medical services, etc. | 5% for essential goods or services such as water, medicine, basic necessities, various agricultural goods / services, technical / scientific services , and so on [2] |
| Laos | 0% for exports of goods except natural resources that have not finished goods[3], electricity imports and electricity exports.[4] | – |
| Indonesian | 0% for Export of All Goods but only for certain Services,
Exempted and/or Not Collected for Basic necessities, clean water, mining goods, certain goods and certain services such as health, finance, education, religion, hospitality, public transportation, imports for re-export purposed goods, etc. |
1% for travel agency services, package delivery and freight forwarding. |
| Phillipines | 0% for Export Sales
VAT exemption for import/delivery of certain drugs, educational readings, medicines and COVID-19 purposes. [5] VAT exemption for the sale of raw goods, packing materials, basic infrastructure services, certain aviation services and sales of environmentally friendly energy. |
1% VAT for entrepreneurs whose business circulation is below the threshold of 3 million Pesos or 832 million Rupiah. After June 30, 2023, it will return to 3% VAT. [6] |
| Cambodia | 0% for exports of goods and services, goods or services industry directly supporting the export of clothing and rice supply.
VAT exemption for health services, electricity, water, public transport, financial services and land. [7] |
– |
| Malaysia | Exempt Sales Tax for all exports of manufactured goods, sales of staple foodstuffs, books, bicycles, minerals, drugs, fertilizers and pesticides. Sales tax is exempt against most Government Officials, armed forces, importers and designated Manufacturers.
Exempt Service Tax for import and export of services.[8] |
5% non-essential foodstuffs and building materials, fruit juices, personal computers, mobile phones and clocks. |
| Myanmar | 0% for exports except electricity (8%) and crude oil (5%)
Commercial Tax Exemption for 43 types of goods and 33 types of services.[9] |
|
| Thailand | 0% for exports of goods and services.
Exempted on unprocessed agricultural products, books, land transportation services, health services, education, professional, technical and research services, libraries, museums, gardens animals, religious services, imports for export, etc. [10] |
|
| Singapore | 0% for international export goods and services
Exempt for sale/lease of unfurnished property, import/supply of precious metals, financial services and digital payments. |
|
| Brunei | No VAT/GST |
The flexibility of VAT provided to the public also needs to be taken into account in comparing the realization of VAT receipts apart from comparing the size of rates among countries. This is because the VAT facility provided will reduce the base of objects that can be income for VAT because the tax object in question has a lower rate or may be exempt or even not subject to VAT at all. Generally, countries in ASEAN, as well as countries globally, provide 0% tariffs for export activities of goods and services. Compared to four countries that have below-average VAT ratios, Indonesia actually provides more VAT facilities.
This actually shows the possibility that Indonesia’s VAT revenue ratio could be lower if Indonesia’s VAT rate is equivalent to these countries though Indonesia chooses to provide more facilities VAT. Against Malaysia and Thailand, Indonesia has more goods and services to be exempt from VAT even though in both countries there are already quite abundant VAT facilities. In contrast to Singapore which does not provide many VAT facilities, especially Brunei which does not apply VAT or VAT equivalent. This can also be interpreted, although Indonesia has high tariffs and may burden the economy, but Indonesia is quite attentive to goods and services that are indeed essential so as to cause more justice while streamlining state income. So, tariffs are indeed important for Indonesia, especially for state revenues that will be channeled by the state, but that does not mean that Indonesia is ignorant of economic development, especially certain economic sectors that are related to the needs of many people that Indonesia cannot interfere with VAT.
Then, based on the data above, it can also be seen that Vietnam’s VAT ratio can be higher even with a lower VAT rate because Vietnam still charges 5% for basic necessities and some specific goods or services while in Indonesia VAT is exempt. Laos’ VAT revenue ratio can also be higher at a low rate because Laos provides few VAT facilities and for exports of Services also remain subject to 10% VAT in contrast to Indonesia applying a 0% tariff according to the provisions of the Minister of Finance. Instead of that, Indonesia can be said to have balanced enough VAT, where Indonesia’s VAT rate is indeed large in order to fulfill the state budget, but at the same time Indonesia also maximizes VAT facilities for certain goods and services that concern the community. In contrast to most ASEAN countries which are fewer than Indonesia in providing VAT facilities. Therefore, a comparison of the realization of other tax sector revenues is needed to provide a comprehensive picture of Indonesia’s tax ratio which is relatively low in the region. Because the VAT sector as the largest sector is actually quite good even though it is with high rates but wrapped in various VAT facilities.
TBrights is a tax consultant in Indonesia which currently is an integrated business service in Indonesia providing comprehensive tax and business services
By Olina Rizki Arizal
Partner
Reference
[1]https://www.dosm.gov.my/v1/index.php?r=column/cthemeByCat&cat=100&bul_id=RkhsOGEwclM4T1UxZ1Vmb0pwL1JlQT09&menu_id=TE5CRUZCblh4ZTZMODZIbmk2aWRRQT09#:~:text=Services%20sector%20was%20the%20main,(25.2%25)%20sub%2Dsectors.
[2] https://taxsummaries.pwc.com/vietnam/corporate/other-taxes
[3] https://taxsummaries.pwc.com/lao-pdr/corporate/other-taxes
[4] https://www.aseanbriefing.com/news/a-guide-to-taxation-in-laos/
[5] https://taxsummaries.pwc.com/philippines/corporate/other-taxes#:~:text=VAT%20applies%20to%20practically%20all,from%20the%20sale%20of%20services.
[6] https://taxsummaries.pwc.com/philippines/corporate/other-taxes#:~:text=VAT%20applies%20to%20practically%20all,from%20the%20sale%20of%20services.
[7] https://taxsummaries.pwc.com/cambodia/corporate/other-taxes#:~:text=Some%20supplies%20are%20VAT%20exempt,primary%20financial%20services%2C%20and%20land.
[8] https://malaysia.acclime.com/guides/sales-service-tax/
[9] https://taxsummaries.pwc.com/myanmar/corporate/other taxes#:~:text=There%20is%20no%20VAT%20in%20Myanmar.
[10] https://www.rd.go.th/english/6043.html
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