VAT Exemptions for Ship Spare Parts in Indonesia: What Maritime Operators Need to Know

Understanding how to secure a vat exemption is essential for international shipping companies delivering technical equipment to vessels calling at Indonesian ports. Importing an urgent ship spare without proper tax documentation can lead to unexpected tariffs, customs holds, and delayed sailing schedules. Equipping every maritime operator with clear regulatory guidance ensures full statutory compliance while optimizing vessel maintenance budgets.

VAT Exempt or VAT Not Collected?

The distinction is important when arranging ship spare parts in Indonesia. Government Regulation PP No. 49 of 2022 provides a VAT-not-collected facility for specified transportation-related goods. In the maritime sector, this can include qualifying vessels as well as their spare parts, ship equipment, navigation safety equipment, and human safety equipment.

The facility can apply to both the importation and domestic supply of qualifying goods when the regulatory conditions are met. For maritime operators searching for “VAT exemptions,” the practical benefit may appear similar because VAT is not collected on a qualifying transaction. Legally, however, the correct treatment should be identified as PPN tidak dipungut where the transaction falls under this facility.

Which Maritime Businesses Can Qualify?

Eligibility is linked not only to the spare parts but also to the company receiving and using them. Under PP No. 49 of 2022 and its implementing framework, the maritime businesses covered include qualifying:

• national commercial shipping companies;
• national fishing companies;
• national port service companies; and
• national river, lake, and ferry transportation companies.

The goods must also be imported or received and used in accordance with the qualifying company’s business activities. This means a marine component does not automatically receive the facility simply because it is intended for installation on a ship. The status of the recipient, its licensed business activity, the vessel involved, and the actual use of the goods should be checked before the transaction proceeds.

What Types of Ship Spare Parts Are Covered?

The regulatory scope extends beyond the vessel itself. For qualifying maritime operations, the framework covers spare parts, ship equipment, navigation safety equipment, and human safety equipment associated with specified vessels. The implementing regulation also identifies vessel categories including sea transportation vessels, river and lake transportation vessels, ferries, fishing vessels, pilot boats, tugboats, and barges.

The actual spare part should still be properly identified in the transaction documents. Operators should avoid assuming that every product described commercially as “marine equipment” automatically falls within the tax facility. Clear identification becomes especially important when multiple types of equipment are consolidated into one shipment.

Imported and Locally Purchased Spare Parts

The VAT facility can apply through two different procurement routes. For imported spare parts, the transaction involves the overseas supplier, importer, shipping documents, customs process, and the applicable Indonesian tax documentation. For spare parts purchased domestically, the transaction involves an Indonesian supplier and the corresponding domestic tax documentation.

The underlying eligibility requirements still need to be satisfied in either case. This is why the VAT position should be checked during procurement planning. If a purchase order has already been issued, payment completed, or goods shipped before the required facility is arranged, correcting the transaction can become more complicated.

SKTD: A Key Document for the Facility

A central document in the process is the Surat Keterangan Tidak Dipungut (SKTD), or Certificate of VAT Not Collected. Under the current Directorate General of Taxes (DGT) administrative guidance, the VAT-not-collected facility for qualifying transportation goods is provided using an SKTD, which applies to the relevant import or supply. The application is processed electronically through the DGT system.

The taxpayer must also meet tax-compliance requirements. Current DGT guidance requires the applicant to have submitted the applicable tax returns and not have outstanding tax debt, unless the debt is covered by an approved postponement or installment arrangement. Under PMK No. 41/PMK.03/2020, the SKTD is issued for each qualifying import or supply. The regulation provides for a decision within a maximum of five working days after a complete application is received, subject to the applicable requirements. This timing should be considered when planning an urgent spare-parts shipment.

What Documents Should Be Prepared?

The documentation differs depending on whether the transaction involves an import or domestic supply.
For imported goods, supporting documents can include:

• invoice;
• Bill of Lading or Air Waybill;
• purchase contract; and
• payment document or document acknowledging the payable amount.

For a domestic supply, supporting documentation can include the purchase order, purchase contract, or equivalent transaction documents. The application also requires information identifying the goods and transaction, such as the type and quantity of goods, import value or selling price, and applicable VAT information. Consistency is important.

For example, if the purchase order uses one description, the commercial invoice another, and the shipping document only states “ship spares,” additional clarification may be needed to establish exactly what goods are involved. A more controlled approach is to align the part description, quantity, value, recipient, supplier, and supporting transaction documents before the shipment proceeds.

What Happens If the Goods Are Used Differently?

Receiving the VAT facility does not mean the goods can subsequently be used without restriction. PMK No. 41/PMK.03/2020 contains provisions addressing goods that received the VAT-not-collected facility but are later used for purposes inconsistent with the original qualifying purpose or transferred to another party under circumstances covered by the regulation. Depending on the situation, VAT that was previously not collected may become payable. For operators, this means compliance continues beyond obtaining the SKTD. Records should allow the company to show that the goods were acquired and used for the qualifying maritime activity.

VAT Treatment and Import Duty Are Different Issues

Another point that can create confusion is the difference between VAT treatment and customs duty treatment. An SKTD concerns the VAT-not-collected facility. It should not automatically be interpreted as confirmation that a shipment is also exempt from import duty. Indonesia has separate customs rules governing import duties and customs facilities. Whether a particular shipment qualifies for another customs facility needs to be checked against the applicable customs regulation and import arrangement. For imported ship spare parts, operators should therefore review several connected issues separately:

VAT facility → customs treatment → importer/consignee → shipping documents → local clearance → vessel delivery

A correct VAT arrangement does not replace the other requirements involved in bringing the goods into Indonesia.

What Should Be Checked Before Shipping?

For an international spare-parts delivery to Indonesia, several points should ideally be confirmed before dispatch.

1. Who will receive the goods?
   Confirm the Indonesian entity involved and whether it meets the eligibility requirements for the facility.
2. What exactly is being shipped?
   Identify the spare parts or equipment clearly rather than relying on a broad description such as “marine spares.”
3. Does the intended use qualify?
   Confirm the vessel and operational purpose for which the goods will be used.
4. Is the SKTD required and ready?
5. Check the applicable tax documentation before shipment or supply rather than trying to resolve the VAT treatment afterward.
6. How will the goods enter and move within Indonesia?
   Confirm the importer or consignee, customs arrangement, transport, port access, and final delivery method.

For urgent vessel requirements, these checks become especially relevant because the vessel’s ETA, supplier schedule, customs processing, and local delivery all need to work within the same timeframe.

Balancia’s Ship Spare Parts Support in Indonesia

Balancia Ship Agency supports the local coordination of ship spare parts deliveries to vessels across Indonesian ports. Depending on the shipment and port call, support can include coordination of shipment documentation, local handling, customs-related coordination with the relevant parties, transportation, port access, and delivery to the vessel.

Where a VAT facility is being used, the taxpayer’s eligibility and tax treatment should be confirmed with the relevant tax adviser and Indonesian tax authorities as required. Balancia can coordinate the operational side of the shipment so the delivery arrangement is aligned with the vessel’s schedule and local procedures.

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References

• Direktorat Jenderal Pajak. (2020). Retrieved from Persyaratan dan Tata Cara Impor dan Penyerahan Alat Angkutan Tertentu serta Penyerahan dan Pemanfaatan Jasa Kena Pajak Terkait Alat Angkutan Tertentu yang Tidak Dipungut Pajak Pertambahan Nilai: https://www.pajak.go.id/id/peraturan/persyaratan-dan-tata-cara-impor-dan-penyerahan-alat-angkutan-tertentu-serta-penyerahan
• Direktorat Jenderal Pajak. (2022). Retrieved from Pajak Pertambahan Nilai Dibebaskan dan Pajak Pertambahan Nilai atau Pajak Pertambahan Nilai dan Pajak Penjualan atas Barang Mewah Tidak Dipungut atas Impor dan/atau Penyerahan Barang Kena Pajak Tertentu dan/atau Penyerahan Jasa Kena Pajak Tertentu dan/ata: https://pajak.go.id/id/peraturan/pajak-pertambahan-nilai-dibebaskan-dan-pajak-pertambahan-nilai-atau-pajak-pertambahan
• PwC. (2022). Retrieved from https://www.pwc.com/id/en/taxflash/assets/english/2022/taxflash-2022-22.pdf: https://www.pwc.com/id/en/taxflash/assets/english/2022/taxflash-2022-22.pdf