Legal Literacy — The Supreme Court (MA) issued Supreme Court Regulation (PERMA) Number 3 of 2025 concerning Guidelines for Handling Criminal Cases in the Field of Taxation. This PERMA was enacted in Jakarta on December 10, 2025 and came into effect on December 23, 2025 or the date of promulgation, with its placement in the State Gazette of the Republic of Indonesia of 2025 Number 1108.

In the general provisions, the guidelines contain definitions of a number of key concepts that often arise in handling criminal cases of taxation, including the definition of "Every Person" which includes individuals and corporations (both as taxpayers and non-taxpayers), as well as the definition of "Third Party" (e.g. banks, public accountants, notaries, tax consultants, and other related parties) and "Other Parties" (parties who order, participate, encourage, assist, or receive benefits). PERMA also affirms that the scope of criminal acts in the field of taxation refers to the regime of the UU KUP and related tax laws.

The Supreme Court stated that these guidelines have four main objectives: to provide guidelines for judges when examining tax criminal cases, to prevent differences in interpretation and application of provisions, to increase the effectiveness of case handling, and to optimize the recovery of losses to state revenue. These objectives also place PERMA 3/2025 as an instrument for standardizing criminal tax justice procedures—from the initial stage to the execution of decisions—so that practices in court are more uniform.

Structurally, PERMA 3/2025 is structured in 6 chapters with a total of 22 articles. In the principles section, the handling of tax criminal cases is affirmed to be based on justice, expediency, certainty, proportionality, transparency, and accountability.

One of the initial emphases is on the framework of criminal responsibility. PERMA affirms that "Every Person" can only be held accountable for criminal acts committed intentionally or due to negligence, while highlighting the element of fault (mens rea) and/or benefits received as considerations for accountability.

For corporations, PERMA broadens the focus of accountability not only to administrators who are formally listed in the organizational structure, but also to parties outside the structure who act as givers of orders, controllers, or beneficial owners who can control the corporation. PERMA also affirms that the termination or death of administrators does not eliminate corporate criminal liability; likewise, bankruptcy or dissolution of the corporation does not automatically eliminate the criminal liability of administrators, controlling personnel, or other related parties for the actions that occurred.