An Indonesian citizen working in the UAE does not stop being an Indonesian tax resident just by staying abroad for more than 183 days. Under the Directorate General of Taxes regulation PER-23/PJ/2025, issued on 9 December 2025, a citizen (WNI) becomes a foreign tax subject (subjek pajak luar negeri, SPLN) only if they also prove tax residence in another country, settle their Indonesian tax, and obtain a letter from the DJP confirming the status. Until then, Indonesia can tax a UAE salary at 5% to 35%, and the 2019 Indonesia to UAE treaty only credits UAE tax, which is zero.
This guide is for Indonesian citizens living and working in the UAE, including domestic workers, hospitality staff, engineers and professionals. It covers who is an Indonesian resident taxpayer, the five conditions for SPLN status and the order in which they are tested, the application, the treaty with the UAE, and what you still owe once you are a foreign tax subject.
The UAE side is simple. The UAE does not tax employment income, as our guide to what a tax-free salary really means explains, so every question here is about Indonesia.
What Changed in December 2025
The DJP published PER-23/PJ/2025 on determining resident and foreign tax subjects, dated 9 December 2025 and in force from that date under its Article 13. Article 12 revoked two older rules:
- PER-2/PJ/2009 on the income tax treatment of Indonesian workers abroad, which many agents and older articles still quote; and
- PER-43/PJ/2011 on determining resident and foreign tax subjects.
If a guide you are reading cites PER-2/PJ/2009 as the rule for Indonesians working in the Gulf, it is out of date.
Who Is an Indonesian Resident Taxpayer
Article 3 of PER-23/PJ/2025 makes an individual, citizen or foreigner, a resident tax subject (subjek pajak dalam negeri) in any of three cases.
| Test | What PER-23/PJ/2025 says |
|---|---|
| Residing in Indonesia (Article 4(1)) | Any one of: a dwelling in Indonesia you control or can use at any time, owned, rented or available, and not a stopover; your main center of personal, social, economic or financial activity in Indonesia; or carrying on your daily habits or activities in Indonesia |
| 183 days (Article 4(2)) | More than 183 days in Indonesia in any 12 months, continuous or not, with part of a day counted as a full day |
| Intention to reside (Article 4(3)) | Present in a tax year with evidence of intent, such as a residence permit, a work contract or a lease of more than 183 days |
A resident is taxed on worldwide income. For most Indonesians in Dubai, the first test is the problem: a family home in Indonesia that is available to you, or your spouse and children living there, can keep you resident however long you stay abroad.
The Five Conditions for Becoming a Foreign Tax Subject
Article 6(1)(c) of PER-23/PJ/2025 treats a citizen as a foreign tax subject if they are outside Indonesia for more than 183 days in any 12 months and meet these conditions.
| No. | Condition | Mandatory? |
|---|---|---|
| 1 | You live permanently in a place outside Indonesia that is not a stopover | Always |
| 2 | Your main center of personal, economic or social ties is outside Indonesia: spouse, children or close family living abroad, income from abroad, or membership of a recognized organization abroad | Only if you still also have a home or center of activity in Indonesia |
| 3 | You carry on your daily habits or activities outside Indonesia | Only if conditions 1 and 2 are met abroad but you also meet them in Indonesia |
| 4 | You are a resident tax subject of another country or jurisdiction | Always (Article 7(2)) |
| 5 | You have settled all tax for your time as a resident and hold the DJP’s letter confirming you meet the SPLN conditions | Always (Article 7(2) and (4)) |
The tiered test in plain terms
Article 7(1) says conditions 1 to 3 are tested “berjenjang”, in tiers, much like a treaty tie-breaker. Condition 1 must always be met. If you no longer have a home or center of activity in Indonesia, you stop there. If you still do, condition 2 decides; if you have a center of activity in both places, condition 3 decides.
Take a nurse in Abu Dhabi who rents an apartment there, whose husband and children live with her, and who has given up her rented room in Surabaya. She meets condition 1 and has no Indonesian home, so conditions 2 and 3 fall away. A driver in Dubai whose wife and children still live in the family house in Central Java meets condition 1, but the house and family in Indonesia mean condition 2 is examined, and his family ties point home.
Condition 4: why the UAE certificate is the key document
Being a UAE tax resident has to be proved with a domicile certificate or another document from the foreign tax authority. Article 7(3) requires it to be in English, show your name, the issue date and the period it covers, and be signed or authenticated by the competent official.
The period it covers must end no more than six months before you apply to the DJP. If the certificate shows no period, its issue date is treated as the period.
In the UAE, that document is the tax residency certificate issued by the Federal Tax Authority. Our UAE tax residency certificate guide covers the 183-day and 90-day tests and how to apply. Without it, condition 4 cannot be met, however long you have lived in the UAE.
How to Apply for SPLN Status
Article 7(5) of PER-23/PJ/2025 leaves the procedure to the Minister of Finance regulation on individual tax subject requirements. The DJP’s own explainer on working abroad identifies that as PMK 18/PMK.03/2021 as amended by PMK 81 of 2024.
- Before you leave, consider making your taxpayer number non-effective. The DJP explainer suggests applying for non-effective status (Wajib Pajak Non Efektif) while you are still in Indonesia, because you cannot apply for SPLN status until you have been abroad for more than 183 days.
- After more than 183 days abroad, get a UAE tax residency certificate. Check that its period ends within six months before the date you will apply.
- Settle any outstanding Indonesian tax. An unpaid assessment (SKP) or tax bill (STP) means condition 5 is not met.
- Submit the application for the letter confirming you meet the SPLN requirements to the tax office (KPP) where you are registered, in person or by post or courier, with the certificate and evidence of your life in the UAE.
- Wait for the decision. According to a DJP article on the SPLN conditions, the KPP decides within 30 calendar days of a complete application; if it does not, the application is deemed accepted and the letter follows within five days.
Under Article 8 of PER-23/PJ/2025, once you qualify you are treated as having left Indonesia permanently, and you are a foreign tax subject from the date you left.
The 2019 Indonesia to UAE Treaty
Indonesia and the UAE signed a new agreement at Bogor on 24 July 2019. Under its Article 30(3) it replaced the 1995 agreement, and it was reported to have entered into force on 19 August 2021, so it applies from 1 January 2022. Many online summaries still quote the 1995 text. We read the 2019 text as reproduced by Ortax.
| Article | What it says | Why it matters to you |
|---|---|---|
| 4(1)(b)(1) | A UAE resident includes “a United Arab Emirates national or an individual who is under the laws of the United Arab Emirates, is considered as a resident” | No nationality condition. An Indonesian treated as resident under UAE law is inside the treaty. |
| 4(2) | Tie-breaker: permanent home, center of vital interests, habitual abode, nationality, mutual agreement | Decides which country wins if both treat you as resident |
| 15(1) | Salary is taxable only in the state of residence unless the work is done in the other state, which may then tax it | If you are a UAE treaty resident, Indonesia cannot tax your UAE salary |
| 23(2) | Relief is by credit for tax paid in the other state | If Indonesia wins the tie-breaker, the credit is worth nothing, because no UAE tax was paid |
| 29 | Principal purpose test | Treaty benefits can be denied for arrangements made mainly to get them |
Article 11 of PER-23/PJ/2025 confirms that when a person is resident in both Indonesia and a treaty partner, residence is decided by the treaty. In practice the DJP route above and the treaty route rely on the same evidence: a UAE certificate and proof that your home and family life are in the UAE.
What a Resident Owes on a UAE Salary
If you remain an Indonesian resident, your UAE salary is added to your other income and taxed at the rates in Article 17 of the Income Tax Law as amended by Law 7 of 2021 on the Harmonization of Tax Regulations (UU HPP).
| Annual taxable income | Rate |
|---|---|
| Up to IDR 60 million | 5% |
| IDR 60 million to 250 million | 15% |
| IDR 250 million to 500 million | 25% |
| IDR 500 million to 5 billion | 30% |
| Above IDR 5 billion | 35% |
A resident reports this in the annual individual return (SPT Tahunan). No UAE tax has been paid, so there is nothing to credit.
Once You Are a Foreign Tax Subject
The DJP’s working-abroad explainer says an SPLN no longer files an annual Indonesian return. Under Article 9 of PER-23/PJ/2025, income you still receive from Indonesia is taxed under the rules for foreign tax subjects, usually by withholding at source. Common examples are interest on Indonesian deposits, dividends from Indonesian companies and rent from Indonesian property.
If you come back to live in Indonesia, you become a resident taxpayer again, and filing an annual return reactivates a non-effective taxpayer number, according to the same explainer.
The Order to Do This In
- Apply the Article 4 tests honestly. Ask whether a home in Indonesia is available to you and where your spouse and children live.
- Get a UAE tax residency certificate after more than 183 days in the UAE, and renew it so its period stays within six months of any application.
- Clear your Indonesian tax position, then apply to your KPP for the SPLN letter.
- If you cannot qualify, file the annual return and pay tax on worldwide income, including your UAE salary, with no credit.
- Keep the file: lease, employment contract, Emirates ID, school records and the DJP letter.
For moving money home, our guide to sending money from the UAE compares channels, and how UAE banks report accounts under CRS explains why the DJP may already know about your UAE accounts.
What We Could Not Verify
- The entry-into-force date of the 2019 treaty. The 19 August 2021 date comes from Orbitax’s treaty news; the DJP treaty list we could reach does not show the UAE.
- Procedural changes under PMK 81 of 2024. The 30-day decision period and deemed acceptance come from a 2021 DJP article under PMK 18/2021; PMK 81 of 2024 amended that regulation for the Coretax system, and we could not read its text to confirm the timeline is unchanged.
- The official text of UU HPP. The JDIH BPK database refused our connections, so the rate table is stated from the law as widely published rather than from a copy we read in this review.
Frequently Asked Questions
Do Indonesians working in the UAE pay tax in Indonesia?
Only if they are still Indonesian resident taxpayers. A citizen abroad for more than 183 days stops being resident only by meeting the SPLN conditions in PER-23/PJ/2025, which include proving UAE tax residence and obtaining a DJP letter.
Is being outside Indonesia for 183 days enough to stop paying Indonesian tax?
No. Being abroad more than 183 days in 12 months is only the starting point. You must also live permanently abroad, be a resident tax subject of another country, settle your Indonesian tax, and hold the DJP’s letter confirming SPLN status.
What is PER-23/PJ/2025?
It is a Directorate General of Taxes regulation dated 9 December 2025 on determining resident and foreign tax subjects. It revoked PER-2/PJ/2009 on Indonesian workers abroad and PER-43/PJ/2011.
What document proves I am a UAE tax resident?
A UAE tax residency certificate from the Federal Tax Authority. For the DJP it must be in English, name you, show the issue date and period, and cover a period ending no more than six months before your application.
Is there a tax treaty between Indonesia and the UAE?
Yes. A new agreement was signed on 24 July 2019 and replaced the 1995 agreement. It treats any individual considered a resident under UAE law as a UAE resident, with no nationality condition.
How much tax would I pay on my UAE salary if I stay an Indonesian resident?
The progressive rates of 5% to 35% under the Income Tax Law as amended by UU HPP, with no credit for UAE tax because none is paid.
Do I still file an SPT once I am a foreign tax subject?
According to the DJP, a citizen confirmed as a foreign tax subject no longer files the annual return. Indonesian-source income is taxed under the rules for foreign tax subjects, usually by withholding.
What happens if I move back to Indonesia?
You become a resident taxpayer again. Filing an annual return automatically reactivates a taxpayer number that was made non-effective.
Official Sources
- Direktorat Jenderal Pajak, PER-23/PJ/2025 on Determining Resident and Foreign Tax Subjects (Indonesian)
- Direktorat Jenderal Pajak, Conditions for Citizens to Become Foreign Tax Subjects (Indonesian)
- Direktorat Jenderal Pajak, Working Abroad: The Tax Rules (Indonesian)
- JDIH BPK, Law 7 of 2021 on the Harmonization of Tax Regulations (Indonesian)
- JDIH BPK, PMK 18/PMK.03/2021 (Indonesian)
- Indonesia to UAE Agreement for the Avoidance of Double Taxation, 2019 (text as reproduced by Ortax)
Information current as of September 2026. Verify with official authorities before proceeding.
This guide is for informational purposes only and is not tax advice. Indonesian and UAE regulations are subject to change. Always verify current requirements with the relevant official authority, or a licensed tax adviser, before proceeding with any filing or transaction.
