The PT PMA Structure: How Foreign Capital Enters Indonesian Development
A PT PMA Perseroan Terbatas Penanaman Modal Asing is an Indonesian limited liability company in which foreign capital participation is permitted under the investment laws of Indonesia. It is the legal vehicle through which PT Dream Paradise Serenity operates and through which foreign investors participate in the Sidemen Serenity development.
The PT PMA is not a workaround or a grey-area arrangement. It is the formal mechanism provided by Indonesian investment law for exactly this class of commercial activity, and it is used by every major international hotel group operating in Indonesia.
Key Structural Characteristics
| Characteristic | Detail |
|---|---|
| Maximum foreign ownership | Up to 100% in tourism accommodation sector (PP 5/2021 Positive Investment List) |
| Minimum registered capital | IDR 10 billion (approximately AUD 1 million) |
| Minimum paid-up capital | IDR 2.5 billion (approximately AUD 250,000) |
| Required directors | Minimum 2 directors at least one may be a foreign national |
| Registration authority | Ministry of Investment (BKPM) via OSS online system |
| Business identification number | NIB (Nomor Induk Berusaha) required before any commercial activity |
| Establishment timeline | 4 to 8 weeks from document submission to operational status |
| Professional establishment cost | AUD 3,500 to AUD 6,000 through experienced Indonesian corporate law firm |
| Annual compliance cost | AUD 8,000 to AUD 15,000 (accounting, tax, BKPM reporting) |
Tax Treatment
| Tax Type | Rate | Notes |
|---|---|---|
| Corporate income tax (PPh Badan) | 22% | On net taxable income reduced rate possible for listed entities |
| Dividend withholding tax | 10% | Domestic rate; may reduce under applicable DTA |
| Indonesia-Australia DTA dividend rate | 10% | For corporate shareholders holding 25%+ of paying company |
| Capital gains on exit (share transfer) | 5% of gross sale price | Applied to gross proceeds not on profit build into exit modelling |
| VAT (PPN) | 11% | Applied to taxable supplies applicable to room revenue, F&B, etc. |
Annual Compliance Obligations
- Quarterly LKPM (Investment Activity Report) to Ministry of Investment during development phase; annual during operations
- Monthly VAT returns (SPT Masa PPN) from date of first taxable supply
- Annual corporate income tax return (SPT Tahunan PPh Badan)
- Annual audited financial statements (KAP-certified) once audit threshold is met
- BPJS Ketenagakerjaan and BPJS Kesehatan contributions for all employees Indonesian social security obligations
Understand How the PMA Structure Applies to Your Investment
Request a private briefing to discuss the specific PMA structuring options for your investment type equity stake, operator JV, or land acquisition model.