The author treats Indonesia’s P2P sector (POJK 77/2016) as a tax-capacity problem: inclusion rhetoric, then a flood of Chinese operators after Beijing crushed a market that fell from 6,600-plus platforms to 29. Outstanding P2P debt is put above IDR 101 trillion, up 26.25% year-on-year. Early 2025 OJK count: 97 legal platforms vs. 543 illegal. Some rates cited at up to 40% a month vs. banks’ 7–8% a year.

PMK 69/2022 looks tight on paper—15% tax on domestic lenders’ interest, 20% for foreign lenders, automatic withholding by registered platforms, VAT on fees—but unregistered operators shift the burden to borrowers who rarely pay. Legal firms eat compliance costs; illegal ones keep the spread.

Deeper leak: transfer pricing from Indonesian units to Chinese parents (management fees, licenses, software, fat intercompany loans) so the local books show little profit. Unregistered platforms have no Indonesian entity for PMK-172/2023 docs; DJP lacks sector benchmarks. The author wants CbCR from Chinese parents, a tighter information deal under the 2001 tax treaty, and a longer net before 2027 automatic exchange—otherwise rent leaves north while Jakarta taxes the shell.

Indonesia’s peer-to-peer lending sector has become a striking case study in the digital age’s most vexing tax challenge: how to capture value from an economy that moves faster than the state’s capacity to monitor it. Introduced in 2016 under Regulation No. 77/POJK.01/2016, P2P online lending promised to drive financial inclusion and innovation in underserved markets. What followed was rapid expansion, fuelled not by domestic entrepreneurship alone, but by a significant influx of........

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