Hotel Bank SP2DK: Account Movements and Revenue Differences

Hotel Bank SP2DK: Explaining Account Movements, Revenue and Data Differences

Main topic: Classifying hotel bank account movements to explain data differences in an SP2DK.

Full background: Business Tax Administration in Bali: Records and Controls.

Continue according to your needs: SP2DK for Hotels and Villas in Bali: A Practical Guide for Owners and Operators and SP2DK Coretax 2026 for Hotels and Villas: Data Triage, Reconciliation and Responses (Indonesian).

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If a hotel receives an SP2DK containing figures related to its bank accounts, do not immediately treat every credit movement as unreported turnover. A hotel account may receive guest payments, OTA settlements, payment gateway payouts, transfers between company accounts, loans, additional owner funding, deposits, vendor refunds, reversals and other transactions with different economic substance.

When handling a hotel bank SP2DK, the finance team’s main task is to establish a traceable connection from each material bank amount to the transaction documents, general ledger, financial statements and relevant tax return (SPT).

Hotel Bank SP2DK: Are All Credit Movements Turnover?

No. A credit movement shows that money has entered the account, but its economic nature and tax treatment must still be determined from the underlying transaction.

Conversely, a hotel should not assume that account information cannot be used in tax compliance supervision.

DJP Has Access to Financial Information, but the Mechanism Must Be Understood Correctly

Minister of Finance Regulation 108 of 2025 on Technical Guidelines for Access to Financial Information for Tax Purposes took effect on 1 January 2026.

For domestic tax reporting of account information, the regulation covers information including:

the account holder’s identity;
the account number;
the reporting financial institution’s identity;
the account balance or value;
aggregate debit and credit movements during the calendar year; and
income associated with the account.

The regulation also provides for financial information, evidence or particulars to be supplied on request for tax purposes, including taxpayer compliance supervision.

A hotel should therefore avoid building its response strategy on the assumption that account data cannot be available during supervision.

Coretax Is Not a Screen Showing Every Daily Bank Transaction

At the same time, a 2024 article published on DJP’s website explained that Coretax is not a system for opening taxpayers’ bank balances and all account movements. That historical explanation should be read alongside the financial information framework applicable from 2026.

The distinction matters. Financial information reporting that includes balances and aggregate annual debit and credit movements is different from displaying every daily transaction in an internet banking interface.

If an SP2DK mentions a particular amount, do not guess the source or level of detail of the data. Read the actual letter and reconcile the figures for which an explanation is requested.

Types of Hotel Bank Account Movements to Classify

Finance can begin with the following classifications:

Type of Credit Movement	Initial Review	Main Documents
Direct booking payment	Match it to the PMS, folio, invoice and revenue recognition period.	PMS, folio and invoice
OTA settlement	Do not automatically equate the settlement with gross booking value or revenue.	OTA settlement and reservation reports
Payment gateway settlement	Match gross transactions, fees, refunds and the amount received.	Payment gateway report and bank statement
Transfer between company accounts	Trace the source and destination accounts so the movement is not counted as a new business transaction.	Bank statements for both accounts
Funds from shareholders or owners	Determine the substance: capital, a loan, reimbursement or another transaction.	Agreements, corporate documents and general ledger
Loan disbursement	Match it to the financing agreement and liability recorded in the ledger.	Loan agreement and bank advice
Guest deposit	Check whether it remains a liability or relates to services already provided.	Deposit ledger and folio
Vendor refund	Check its connection with an earlier expense, asset or transaction.	Vendor credit note and invoice
Bank reversal or correction	Trace the original transaction and ensure the movement has been reconciled.	Transaction references and bank reconciliation

Terminology note: In banking, bank advice means a bank notification or transaction advice. Depending on the document, a disbursement confirmation may be the more precise term.

This table is an internal screening tool, rather than an automatic tax classification.

Guest Receipts, OTA Settlements and Payment Gateways

For operational administration, do not rely solely on the description attached to a bank transaction.

One OTA settlement can contain many reservation IDs. A payment gateway may also pay a net amount after fees, refunds or chargebacks.

Use the following sequence:

Reservation → invoice/folio → OTA or gateway payment → settlement → bank account → general ledger.

For complex OTA transactions, the OTA reconciliation guide for hotels and villas provides a framework from booking through bank receipt to the general ledger.

Internal Transfers, Loans, Owner Funding and Deposits

Credit movements may also arise from transactions other than room sales.

For example, a company transfers IDR 300 million from operating account A to operating account B. If finance adds all credits in account B to revenue, the same funds may be counted again.

Likewise, loan disbursements or funds from shareholders should not immediately be labelled turnover simply because they appear as incoming transfers. Their substance must be supported by contracts, corporate documents, the counterparty account and ledger entries.

Guest deposits also require analysis of the substance and status of the transaction. Do not automatically include or exclude a deposit from revenue based only on the account name.

Building a Reconciliation from Bank Accounts to the Tax Return

The purpose of reconciliation is not to make every bank figure equal revenue. It is to ensure that every difference can be explained.

Use the following reconciliation trail:

Bank movement → counterparty/reference identification → transaction documents → PMS/OTA/payment gateway → accounting journal → general ledger → financial statements → tax working papers → SPT.

Example Bank Reconciliation Working Paper

Date	Bank Reference	Credit Amount	Initial Classification	Supporting Source	GL Account	Status
5 January	OTA Settlement 001	IDR 85,000,000	OTA settlement	OTA report	OTA receivables	Matched
8 January	Account B Transfer	IDR 150,000,000	Internal transfer	Source bank account	Cash/Bank	Matched
10 January	Guest Deposit	IDR 20,000,000	Guest deposit	PMS and deposit ledger	Guest deposits	Review needed
15 January	Shareholder Transfer	IDR 250,000,000	Owner funding	Agreement and bank evidence	Not final	Review needed
20 January	Direct Booking	IDR 15,000,000	Guest receipt	Folio and PMS	Revenue/related receivable	Matched

These amounts are illustrative. Accounting and tax decisions must follow the actual facts and transaction documents.

How Can a Hotel Explain Differences Between Bank Movements and Revenue?

Bank statements and revenue reports can differ even when the company’s records are correct.

Timing Differences Are Not Automatically Unreported Revenue

Examples of timing differences include:

a guest checks out at month end, but the OTA pays in the following month;
a payment gateway takes several days to settle;
a refund is processed after the original transaction;
a deposit is received before the service is provided;
one payout includes bookings from several periods; and
a foreign currency transfer is credited after conversion.

Annual and monthly comparisons must therefore use consistent cutoffs.

Bank Accounts Can Contain Non-Revenue Transactions

Some incoming transfers may relate to:

fund transfers between the company’s own accounts;
loans;
additional shareholder funding;
repayments or other returned funds;
vendor refunds;
deposits returned by other parties; and
bank corrections or reversals.

A statement that these transactions are not revenue still requires evidence. A manually entered label such as owner transfer in a spreadsheet is insufficient when a material amount is being questioned in an SP2DK.

Documents to Prepare for a Hotel Bank SP2DK

The documents should follow the issues raised in the letter. Internally, a hotel can prepare:

the SP2DK and its attachments;
bank statements for the relevant period;
bank reconciliations;
the general ledger and trial balance;
financial statements;
relevant SPT returns;
PMS or reservation reports;
OTA reports;
payment gateway reports;
invoices and guest folios;
the deposit ledger;
loan agreements where loan disbursements are involved;
owner funding or shareholder transaction documents, where relevant;
evidence of transfers between accounts;
refund and cancellation documentation;
reconciliation working papers; and
a summary explaining each material difference.

This is an internal preparation checklist, rather than a universal list of attachments required by DJP for every SP2DK.

The SP2DK guide for hotels and villas in Bali discusses the wider process of handling the letter, including separating the issues and preparing a response.

When Does a Difference Require a Tax Correction?

Once the bank reconciliation is complete, the review findings can be grouped into three situations.

First, the difference can be explained and the reporting is correct. For example, a high total of bank credits comes from transfers between accounts that can be traced to the source account.

Second, there is an accounting error that does not automatically change the tax position. For example, an internal transfer was incorrectly credited to revenue but was corrected before the relevant tax return was prepared.

Third, the review finds a transaction that was incorrectly recorded or reported and affects a tax obligation. In this situation, the company needs to determine the correction or other action required for the actual tax type and period.

DJP explains that an SP2DK provides an opportunity for taxpayers to clarify the data or make a correction where the review establishes an error.

The decision to correct should therefore follow the review findings, rather than merely the fact that total bank credits exceed a particular revenue figure.

Response Deadlines and Coretax

Minister of Finance Regulation 111 of 2025 provides the compliance supervision framework effective from 1 January 2026.

Respond Within the Applicable 14-Day Period

For registered taxpayers, the regulation provides up to 14 days from the earliest applicable delivery event: issuance in the Taxpayer Account, dispatch to registered email, the date shown on fax or postal/courier dispatch evidence, or direct delivery. Check the actual letter and delivery records; a general reference to the letter’s publication date does not capture every delivery channel.

The response period may be extended by up to 7 days through written notification submitted before the original deadline expires.

When bank accounts have high transaction volumes, do not wait until the last day to begin matching the records.

Retain the BPE and Final Document Versions

DJP provides a service for submitting an SP2DK response through Coretax.

After a successful submission, the system issues an Electronic Receipt, or Bukti Penerimaan Elektronik (BPE).

Keep the following together:

the final response letter;
the final reconciliation working papers;
the attachment list;
the attachment files actually submitted; and
the BPE.

Version control matters so the company does not retain competing spreadsheets with different figures after the response has been submitted.

Mistakes to Avoid

The following mistakes can weaken the company’s explanation:

treating every bank credit as turnover;
assuming DJP has no access to account information;
conversely, assuming officials see every daily movement through Coretax;
comparing total bank credits directly with turnover in the SPT without classification;
failing to eliminate transfers between company accounts;
describing funds as owner financing without supporting documents;
describing funds as a loan without a loan agreement or relevant evidence;
excluding deposits from revenue without examining their substance;
providing only bank statements without a reconciliation trail; and
amending the SPT before the cause of the difference is properly understood.

Conclusion

A hotel bank SP2DK should be answered through transaction reconciliation, rather than a simple comparison of total bank credits with reported turnover.

DJP has a framework for accessing financial information under PMK 108 of 2025, including specified information on balances and aggregate debit and credit movements. That does not establish that Coretax displays every detail of a company’s bank account movements in real time.

For a hotel, the most defensible approach is to classify every material movement and connect it to PMS, OTA and payment gateway reports, contracts, invoices, the deposit ledger, counterparty accounts, the general ledger, financial statements and SPT returns. Once that reconciliation is complete, the company can determine whether a difference needs clarification, an accounting correction or action affecting its tax obligations.

Does Your Hotel’s SP2DK Identify Bank Account Differences?

If account movements cannot yet be reconciled with the PMS, OTA, payment gateway, general ledger, financial statements or SPT, a useful first step is to classify each material transaction and build the reconciliation before submitting a response.

Usman Tax provides hotel tax reporting services and accounting services for hospitality businesses in Bali. A consultation can cover the SP2DK, bank statements, reconciliation working papers and data consistency based on the company’s actual transactions.

Read Also: Business Tax Administration in Bali: Records and Controls

FAQ Hotel Bank SP2DK Explaining Account Movements, Revenue and Data Differences

Does DJP Treat Every Credit in a Hotel Bank Account as Turnover?

That should not be assumed. Bank accounts can contain revenue and other transactions, including internal transfers, loans, owner funding, deposits, refunds and reversals. Each transaction needs to be classified and supported according to its substance.

Does DJP Have Access to Bank Account Information?

Yes. PMK 108 of 2025 provides a financial information access framework for tax purposes. It covers automatic reporting of specified information and a mechanism for obtaining information on request.

Can DJP See Every Hotel Bank Movement in Real Time through Coretax?

It should not be described that way. The 2024 article on DJP’s website distinguished Coretax from a system for opening all bank balances and movements. PMK 108 of 2025 governs specified financial information, including balances and aggregate annual debit and credit movements, and information requests.

Should Transfers Between Company Accounts Be Excluded from Turnover?

An internal transfer should not automatically be treated as a new sale. However, the company must be able to show the source account, destination account, date, amount and ledger entries so the movement can be traced.

How Should Owner Funding Received in the Hotel Account Be Explained?

First identify the substance of the transaction, such as a capital contribution, shareholder loan, reimbursement or another transaction. Prepare the corporate documents, agreements, transfer evidence and consistent accounting records.

Is an OTA Settlement the Same as Hotel Revenue?

Not automatically. A settlement may be a net amount after commissions, refunds, adjustments or other fees. Match reservation reports, gross bookings, settlement reports, bank statements and the ledger before drawing a conclusion.

Is a Guest Deposit Credited to the Account Turnover?

The answer cannot be determined merely because money has been received. The hotel needs to examine the transaction’s rights and obligations, reservation status, refundability, folio and deposit records to determine the appropriate treatment.

Does Receiving an SP2DK Mean the Company Must Immediately Amend Its SPT?

No. The company can clarify a position that is explained and supported by evidence. A correction is considered where the review establishes an error in reporting or payment.

What Is the Deadline for Answering an SP2DK?

For registered taxpayers under PMK 111 of 2025, the response period is up to 14 days from the earliest applicable account issuance, email dispatch, evidenced fax or postal/courier dispatch, or direct delivery event. An extension of up to 7 days requires written notification before the original period expires.

Which Documents Matter Most When Explaining Hotel Bank Accounts?

The documents depend on the SP2DK issues. They commonly include bank statements, bank reconciliations, the general ledger, financial statements, PMS reports, OTA or payment gateway reports, invoices, contracts, the deposit ledger, internal transfer evidence, relevant owner funding or loan documents, and working papers explaining each material difference.