On 5th July, Global Financial Integrity reported that, in a comprehensive new study on the level of trade misinvoicing – the deliberate falsification of the value, volume, and/or type of commodity in an international commercial transaction of goods or services – in Indonesia in 2016, GFI found that the estimated potential tax revenue losses to the Indonesian government that year is approximately $6.5 billion, equivalent to 6.0% of Indonesia’s total government revenue collections in 2016.  It says that approximately $3.9 billion was due to export misinvoicing and approximately $2.6 billion was due to import misinvoicing.  Some of the Indonesian imports most at risk for high values of import under-invoicing were essential oils, vehicles, and plastics; and from China, Japan and Singapore.  Under-invoiced imports of beverages and essential oils from Singapore, plastics from China and vehicles from Japan and China were highlighted as potential high-level risks for revenue losses.

The study itself is available at –

Meanwhile –


The Jakarta Post on 5th July reported that the government is set to intensify its crackdown on people hiding behind business entities for corruption, money laundering and tax evasion following the signing of an inter-ministerial agreement on sharing information on corporations’ beneficial owners.  An MoU allows other ministries to synchronise data with the Law and Human Rights Ministry’s database on business ownership.  In 2018, Indonesia enacted regulations on the Implementation of the Principle of Knowing Beneficial Owners of Corporations in Relation to the Prevention and Eradication of Money Laundering and Terrorism Financing Crimes.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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