Critical Changes to Preliminary Tax Refund Rules & Action Required (MoF-28/2026)
On 30 April 2026, the Ministry of Finance issued Regulation No. 28 of 2026 (“MoF-28”) concerning the Procedures for Preliminary Tax Refunds. Effective 1 May 2026, this new regulation completely revokes the previous framework under MoF Regulation No. 39/PMK.03/2018.
While MoF-28 retains the three categories of eligible taxpayers, it significantly tightens the eligibility thresholds, removes certain automatic privileges, and narrows the overall population of taxpayers who qualify for preliminary refunds.
Taxpayers who no longer qualify should follow the standard refund process, triggering a full tax audit that can take up to 12 months, creating a substantial cash flow disadvantage for businesses with recurring VAT overpayments
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