Bali Hotel Tax Audit: A Guide for Owners and Management

Bali Hotel Tax Audit: A Practical Guide for Owners and Management

Main topic: Preparing for a hotel tax audit, taxpayer rights and the coordination of audit documents.

Full background: Business Tax Administration in Bali: Bookkeeping, Reporting and Document Controls.

Continue according to your needs: SP2DK for Hotels and Villas in Bali: A Practical Guide for Owners and Operators, PT PMA Hotel Tax Due Diligence: A Checklist for Directors and Investors.

Assistance is available through our business tax consultation service.

Receiving a tax audit notice can be a serious situation for hotel owners and management. However, an audit should not be approached with panic or by sending as many documents as possible without a strategy. A more appropriate first step is to understand the type of audit, the period under examination, the taxes within its scope and the data that needs reconciliation.

In a Bali hotel tax audit, the challenge often lies in the volume of transactions and the number of data sources. Revenue may come from direct bookings, Online Travel Agents or OTAs, corporate bookings, restaurants, spas, events and additional services. That information then flows into the property management system, bank accounts, general ledger, financial statements and tax reporting.

Audit readiness therefore involves more than having documents available. A hotel needs to demonstrate a logical connection between its operational transactions, accounting records and tax reporting.

Bali Hotel Tax Audit: What Is Actually Examined?

Under PMK 15 of 2025 on Tax Audits, an audit involves collecting and processing data, information and/or evidence objectively and professionally, according to audit standards, to test compliance with tax obligations or for other purposes.

In practice, an audit may cover one, several or all tax types for one or more tax periods or tax years, depending on its basis and type.

For a hotel, this means management should not assume that every audit covers all company transactions. First examine the Tax Audit Notification Letter and the information provided to the taxpayer about the audit scope.

Distinguish a Tax Audit from SP2DK

SP2DK and a tax audit are different processes.

SP2DK is a request for an explanation of data and/or information. A tax audit is a formal process with procedures, rights and obligations, time limits, examination of data, communication of findings and a final discussion.

For hotel owners still at the data clarification stage, Usman Tax’s SP2DK guide for hotels and villas in Bali discusses that process specifically.

If the hotel has received a Tax Audit Notification Letter, its document management and response should be adapted to the audit process under the applicable rules.

Three Types of Tax Audit under PMK 15 of 2025

Under DJP’s tax audit provisions, audits to test compliance are divided into three types.

A Complete Audit (Pemeriksaan Lengkap) examines all items in the tax return (SPT) and/or Tax Object Notification Form (SPOP) in depth. Its examination stage lasts no longer than five months.

A Focused Audit (Pemeriksaan Terfokus) examines one or several specific items in depth. Its examination stage lasts no longer than three months.

A Specific Audit (Pemeriksaan Spesifik) uses a simpler approach to examine one or several particular items, data points or tax obligations. Its examination stage lasts no longer than one month.

After the examination stage, the final discussion of audit findings and reporting generally take no longer than 30 working days. Certain circumstances have different time limits, so the company must still check the actual type and basis of its audit.

Bali Hotel Tax Audit: Start with the Letter and Scope

When facing a Bali hotel tax audit, management should not immediately start with accounting folders or bank statements. Begin with the audit documents.

Identify:

the taxpayer being audited;
the tax period or year;
the kind or type of audit;
the tax types within scope;
the particular items or data if the audit is focused;
the members of the audit team; and
the document requests already issued.

Once the scope is understood, the company can create a working file for each issue. This approach helps finance, accounting, management and the advisers supporting the audit use consistent figures and explanations.

Bali Hotel Tax Audit: Internal Document Checklist

The documents that must actually be supplied depend on the auditors’ requests and the audit scope. As an internal preparation checklist, a hotel can review:

tax returns and tax documents for the relevant period;
the general ledger and trial balance;
financial statements;
company bank statements;
room revenue reports;
property management system reports;
OTA settlement reports;
direct booking reports;
sales and purchase invoices;
contracts with relevant vendors or other parties;
payroll and employee transaction documents, if within scope;
the asset register, if related to the items under examination; and
working papers reconciling operational, accounting and tax data.

This list does not mean every document must automatically be handed over. Prioritise the documents actually requested or relevant to the audit scope.

Which Hotel Data Needs Reconciliation?

A hospitality business has several layers of data that can produce different figures if they are not properly reconciled.

For example, an OTA’s gross booking amount is not always the same as the net cash received by the hotel. Commissions, refunds, cancellations, adjustments or settlement differences may be involved. Management needs to understand how these transactions are recorded from the reservation report through to the general ledger.

Reconciliations may include:

the PMS or reservation system against revenue reports;
OTA reports against settlements received;
settlements against bank statements;
bank statements against the general ledger;
the general ledger against the financial statements; and
the financial statements against the data used in tax reporting.

The same applies to restaurants, spas, events and other revenue units if they fall within the audit scope.

For a more organised hotel administration process, Usman Tax’s Bali hotel tax reporting service page provides context on tax reporting and the reconciliation of hotel operating reports.

The Hotel’s Rights and Obligations During an Audit

A taxpayer’s role is not limited to supplying data. Under PMK 15 of 2025, taxpayers also have a number of rights during an audit.

Among other rights, a hotel may ask auditors to show their Tax Auditor Identification Cards and Audit Order, receive the Tax Audit Notification Letter, be informed of changes to the audit team and obtain an explanation of the reasons for and purpose of the audit.

In a compliance audit, the taxpayer also has rights to receive audit findings, participate in certain discussion stages, receive the Notification of Audit Findings (SPHP) and attend the final discussion of audit findings, according to the circumstances and audit type.

As part of its obligations, the taxpayer may be required to present or lend books, records, documents and electronic data relevant to its business activities or the subject of the audit. PMK 15 of 2025 also requires documents covered by a written request to be supplied no later than one month after the request letter is delivered.

The company should therefore appoint one person in charge to control outgoing documents, log auditors’ requests, record delivery dates and keep the versions supplied consistent.

What Happens When the Hotel Receives an SPHP?

The findings of a compliance audit must be communicated through a Notification of Audit Findings, or SPHP, accompanied by a list of audit findings.

PMK 15 of 2025 requires the taxpayer to submit a written response to the SPHP and list of findings no later than five working days after receiving the SPHP.

This stage matters because the company can assess each proposed adjustment and determine whether it:

agrees with the findings;
agrees in part;
disagrees with particular findings; or
needs to provide additional relevant documents and arguments under the procedure.

The process then continues to the final discussion of audit findings. Because the SPHP response period is relatively short, the hotel should not wait until receiving it to begin understanding its transactions. Working papers and reconciliations need to be prepared during the examination stage.

Mistakes to Avoid During an Audit

Some mistakes can make the audit more difficult:

providing documents without recording what was handed over;
using different figures across finance, accounting and the tax team;
giving verbal explanations that have not been verified;
assuming every difference automatically represents a tax error;
supplying large volumes of data without understanding their relevance;
failing to read the audit scope;
ignoring letters or response deadlines;
starting reconciliations only after the SPHP arrives; and
mixing national tax issues with local tax obligations.

Usman Tax also has an article on common hotel tax mistakes in Bali, which can be used for an internal review before a formal audit.

DJP Audits and Local Hotel Tax Audits Are Different

For hotels in Bali, the term tax audit can refer to two different areas.

This article primarily discusses audits conducted by the Directorate General of Taxes on taxes administered by DJP under PMK 15 of 2025.

A hotel may also have local tax obligations. Local tax audits have their own framework. At national level, PMK 7 of 2025 provides guidelines for local tax audits and collection, while the actual implementation must be considered alongside the local rules applicable to the hotel’s location.

When an audit letter arrives, the first step is therefore to establish which authority issued it and which tax types are being examined.

Effective management of a Bali hotel tax audit ultimately depends on three things: understanding the audit scope, having data that can be reconciled and providing explanations supported by consistent documents. Structured preparation is much more useful than attempting to answer each question spontaneously without clear working papers.

Are You Facing a Bali Hotel Tax Audit?

If your hotel has received a Tax Audit Notification Letter, review the scope, reconcile the data and check the documents before explaining the position or supplying information to the auditors.

Usman Tax provides tax reporting and accounting services for hospitality businesses in Bali. A consultation can address the audit letter, document readiness, transaction reconciliations, SPHP and the administrative steps to prepare for the company’s particular circumstances.

Read Also: Bali Tax Consultant: Professional Support for Business and Corporate Tax Compliance

FAQ Bali Hotel Tax Audit

What is a hotel tax audit?

A tax audit involves objectively and professionally collecting and processing data, information or evidence to test tax compliance or for other purposes under the rules. For a hotel, its scope depends on the letter and the tax types being examined.

Is a tax audit the same as SP2DK?

No. SP2DK requests an explanation of data and/or information, while an audit is a formal process involving procedures, audit types, time limits, examination, SPHP and discussion of the findings.

What audit types are provided under PMK 15 of 2025?

Compliance audits are divided into Complete Audits, Focused Audits and Specific Audits. Their scopes and examination periods differ.

How long can a tax audit take?

Generally, the examination stage lasts no longer than five months for a Complete Audit, three months for a Focused Audit and one month for a Specific Audit. The final discussion and reporting generally take no longer than 30 working days. Certain exceptions must be checked against the actual basis of the audit.

Which documents does a hotel usually need to prepare?

The documents depend on the request and audit scope. Internally, a hotel can prepare relevant tax returns, financial statements, general ledger, trial balance, bank statements, PMS reports, OTA settlements, invoices, contracts, payroll and reconciliation working papers.

Should OTA data be checked before a tax audit?

If OTA revenue relates to the period or item under examination, reconcile OTA data with the reservation system, settlements, bank statements, accounting and tax reporting. This allows the company to explain any differences that arise.

What rights does a hotel have during a DJP audit?

Among other rights, the taxpayer may inspect auditors’ identification and the Audit Order, receive the Tax Audit Notification Letter, obtain an explanation of the reasons and purpose, and receive and discuss findings under the applicable procedure.

How long is the response period for an SPHP?

PMK 15 of 2025 requires a written response to the SPHP and list of audit findings no later than five working days after the SPHP is received.

Is a DJP hotel tax audit the same as a hotel PBJT audit?

Not necessarily. DJP audits concern taxes within DJP administration, while PBJT on hotel services is a local tax. Local tax audits have their own framework and provisions, which must be checked for the relevant regional authority.

When should a hotel seek professional assistance during an audit?

Assistance may be worth considering when transactions are complex, numerous revenue sources need reconciliation, documents are inconsistent, proposed adjustments are material, management does not understand the SPHP, or the company needs help managing documents and responses systematically.