Tax Account Freeze: Causes and How to Resolve It

In recent times, the Indonesian government has intensified active tax collection from taxpayers with arrears. One of the most noticeable measures is the rising frequency of tax account freezes as part of enforcing tax compliance. For many business owners, a tax account freeze can significantly disrupt cash flow and daily operations.

A tax account freeze is not an abrupt action. Every step is carried out based on legislation, through a clear and sequential administrative process. By understanding these stages, taxpayers can anticipate risks early and make the right decisions.

Account Freezing

Bank accounts can only be frozen after the Directorate General of Taxes (DGT) issues a Forced Letter, an official document ordering the taxpayer to settle their tax debt within 2×24 hours. If the obligation is still not fulfilled within this period, DGT can continue active tax collection, starting from freezing bank accounts, seizing assets, to auctioning.

This process is clearly regulated in:

• Law No. 19 of 1997 jo. Law No. 19 of 2000 on Tax Collection with Forced Letters (UU PPSP)
  Regulates stages from Tax Assessment Letter, Forced Letter, asset seizure, to auction.
• Minister of Finance Regulation (PMK) Number 61 of 2023 on Procedures for Tax Collection of Unpaid Taxes
  Confirms that DGT can request banks to freeze accounts as part of active collection measures.

Thus, a tax account freeze is carried out only after a long administrative sequence, starting from STP/SKP, Tax Notice, to Forced Letter. Many taxpayers are unaware because letters are unopened, addresses outdated, or considered unimportant.

The main purpose of account freezing is to ensure funds are available to settle tax arrears. Bank accounts are considered liquid and easily used to guarantee debt settlement. Government Regulation (PP) No. 135 of 2000 states that bank accounts, savings, checking accounts, deposits, and other forms of savings can be seized or frozen. Freezing also prevents taxpayers from transferring funds before the seizure process. However, all actions must be based on official regulations, including notifying the bank and recording in DGT’s administration.

Also Read: Tax Audit Efficiencies Based on PMK 15/2025

Legal Measures That Can Be Taken

When an account is frozen, the first step is to remain calm and focus on identifying the cause. Freezing always has an administrative basis, so understanding the reason behind it will help determine the most appropriate resolution.

The initial stage involves reviewing all correspondence from DGT, such as Tax Notices, Forced Letters, or other notifications. If documents have not been received or are unreadable, taxpayers can contact the examiner, the collection division, or the tax office to confirm the official basis for the freeze.

After understanding the cause, taxpayers can meet directly with DGT officials to explain their situation, verify data, and express intent to settle obligations. Effective communication is crucial, as many freezing cases can be resolved faster through clarification and administrative negotiation.

If financial conditions do not allow full payment, taxpayers may submit a request for installments or defer the payment of tax debts, as regulated under Article 9, paragraphs (4) and (5) of the General Tax Provisions and Tax Procedures Law (UU KUP). If procedural or calculation errors are found, taxpayers can also request cancellation of collection actions under UU PPSP and PMK 61/2023.

In certain cases where freezing relates to alleged tax crimes, investigative mechanisms under Article 44 UU KUP may serve as the basis for freezing. In such situations, professional assistance and formal clarification are critical before taking further legal steps.

Role of Legal Counsel

Account freezing by tax authorities often causes panic, especially for businesses dependent on daily cash flow. In this context, professional assistance with deep knowledge of tax collection regulations is crucial. Competent legal counsel or certified tax consultants help taxpayers take the right steps while minimizing the risk of misstatements when communicating with DGT.

Certified tax consultants have the expertise to:

• Analyze the administrative and legal basis of the account freezing.
• Ensure DGT collection procedures comply with applicable regulations.
• Act as an objective intermediary in communications with tax officers to avoid statements that may worsen legal positions.
• Develop safe, proportional, and financially appropriate tax debt resolution strategies.
• Provide preliminary consultation before taxpayers meet at the tax office, ensuring data and explanations are consistent and not harmful.
• Prepare and submit administrative requests, such as installments, deferrals, or objections to collection actions.

Ideal assistance is provided by legal counsel or certified tax consultants holding a Bersertifikat Konsultan Pajak (BKP) license. Authority is officially delegated through a Power of Attorney, as regulated in 229/PMK.03/2014 on Appointment and Termination of Tax Power of Attorney. With a valid power of attorney, the consultant has legal standing to represent and act on behalf of the taxpayer before DGT. Legal counsel not only assists administratively but also provides reassurance, protection, and certainty in decision-making.

PT Synergy Ultima Nobilus is ready to assist you in handling various tax issues. Our certified tax consultants provide reliable and professional solutions. Contact us for more information.