Cryptocurrency Reporting and Verification Risks in Indonesia's Annual Income Tax Returns

Abstract

Cryptocurrency taxation raises a policy question for Indonesia's Annual Income Tax Returns: how can asset-disclosure duties be supported and verified when holdings move between centralized exchanges (CEXs) and private wallets? This study uses a document-based qualitative approach, drawing on academic and legal sources, public data, hypothetical scenarios, and transaction screenshots within the historical 2022-2023 regulatory context. The analysis illustrates two information gaps: a year-end CEX balance may exclude holdings kept elsewhere, and traceable on-chain transfers do not independently establish taxpayer identity or ownership. The policy implication is to combine guidance covering both custody arrangements with proportionate, corroborated verification. Linking enforced and voluntary compliance instruments, the study proposes worked filing examples, a holdings-reconciliation worksheet, documented review of discrepancies, and targeted information requests through applicable legal channels. A conceptual matrix connects the illustrated risks to administrative actions and expected case outputs. Prospective evaluation would examine reporting accuracy, unresolved discrepancies, and administrative and taxpayer costs before broader implementation. The illustrations do not measure prevalence, establish intent, or demonstrate policy effectiveness. Additional duties to disclose quantities or wallet addresses would require a defined legal basis and assessment of proportionality and feasibility.