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An Anti-Facilitation of Tax Evasion Policy sets clear rules and procedures to prevent companies and their employees from helping others avoid taxes illegally. In Indonesia, these policies align with Law No. 11 of 2016 on Tax Amnesty and support the government's efforts to combat tax crimes and money laundering.

The policy requires businesses to implement strict due diligence measures, train staff on spotting red flags, and establish reporting channels for suspicious activities. It helps organizations protect themselves from legal penalties while demonstrating their commitment to good corporate governance and Indonesia's broader tax compliance framework.

Companies operating in Indonesia need an Anti-Facilitation of Tax Evasion Policy when they conduct business with multiple partners, handle large financial transactions, or operate across different tax jurisdictions. This is especially crucial for sectors like financial services, real estate, and international trade where complex transactions increase tax evasion risks.

The policy becomes essential when expanding operations, onboarding new business partners, or facing increased regulatory scrutiny from Indonesia's tax authorities. It provides vital protection during tax audits, helps maintain compliance with Law No. 11 of 2016, and safeguards against potential involvement in money laundering schemes through clear operational guidelines.

• Basic Policy: Core version focused on fundamental tax evasion prevention measures, internal controls, and reporting procedures - ideal for small to medium enterprises
• Comprehensive Corporate Policy: Enhanced version with detailed risk assessment frameworks and cross-border transaction protocols, suited for large corporations
• Financial Services Variant: Specialized version with additional due diligence requirements for banks and financial institutions under OJK regulations
• Group-Wide Policy: Adapted for Indonesian business groups with multiple subsidiaries, including inter-company transaction controls
• Industry-Specific Policy: Customized versions for high-risk sectors like real estate, mining, and international trade with sector-specific compliance measures

• Board of Directors: Responsible for approving and overseeing the Anti-Facilitation of Tax Evasion Policy, ensuring corporate-wide compliance
• Compliance Officers: Draft, implement, and monitor the policy, conduct risk assessments, and maintain documentation
• Finance Teams: Apply policy guidelines in daily operations, flag suspicious transactions, and maintain accurate records
• HR Departments: Coordinate staff training on policy requirements and manage internal reporting channels
• External Advisors: Tax consultants and legal counsel who help align the policy with Indonesian tax regulations and best practices

• Risk Assessment: Map out your organization's tax-related activities, business relationships, and potential risk areas
• Legal Framework: Review current Indonesian tax laws, especially Law No. 11 of 2016 and related regulations
• Internal Structure: Document your company's reporting lines, decision-making processes, and control mechanisms
• Training Needs: Identify key staff positions requiring detailed policy training and compliance awareness
• Monitoring Systems: Plan how you'll track policy compliance, including reporting tools and review procedures
• Documentation: Gather existing policies, procedures, and forms that need integration with the new policy

• Policy Statement: Clear declaration of zero tolerance for tax evasion facilitation and commitment to Indonesian tax compliance
• Scope and Application: Detailed coverage of affected employees, business units, and activities
• Risk Assessment Framework: Methodology for identifying and evaluating tax evasion risks
• Due Diligence Procedures: Steps for vetting business partners and transactions
• Reporting Mechanisms: Procedures for reporting suspicious activities and protection for whistleblowers
• Training Requirements: Mandatory staff training schedules and documentation requirements
• Enforcement Measures: Consequences for policy violations and disciplinary procedures

While both policies address corporate compliance, an Anti-Facilitation of Tax Evasion Policy differs significantly from a Compliance and Ethics Policy. Here are the key distinctions:

• Scope and Focus: Tax evasion policies specifically target financial transactions and tax-related risks, while compliance and ethics policies cover broader ethical conduct across all business operations
• Legal Framework: Tax evasion policies directly align with Indonesian tax laws and DJP regulations, whereas compliance and ethics policies address multiple regulatory frameworks
• Risk Assessment: Tax evasion policies require detailed financial risk monitoring and transaction screening, while compliance policies focus on general operational risks
• Implementation Requirements: Tax evasion policies demand specific financial controls and reporting mechanisms, compared to the broader organizational guidelines in compliance policies