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VOL. 12, ISSUE 4 (2026)
Tax dispute resolution and the principle of justice: A normative juridical analysis of the Indonesian tax court system
Authors
Norma Rani Kusumawardhani Zoulba, Budi Ispriyarso
Abstract
Tax disputes test whether the state’s power to collect revenue can coexist with taxpayers’ right to contest assessments, yet Indonesia’s system suffers from lengthy proceedings and a Tax Court divided between two overseers. Constitutional Court Decision No. 26/PUU-XXI/2023 now requires consolidation under the Supreme Court by 31 December 2026. This study examines whether the norms on objection, appeal, and the Court’s institutional position realise justice, and formulates a normative reconstruction. A normative juridical method combining statute, case, and conceptual approaches is applied to Law No. 14 of 2002, Law No. 48 of 2009, the constitutional decision, and scholarly literature. Findings show strong procedural guarantees of hearing, evidence, and reasoned decisions, but access is constrained by a fifty percent payment requirement, continued collection, a keberatan stage within the assessing authority, and extendable time limits. The transfer to the Supreme Court removes the structural conflict of interest, yet impartiality also depends on objection reform, judicial competence, and statutory harmony. The study concludes that justice is better secured in text than in practice, and recommends integrated statutory harmonisation, transitional safeguards, a proportionate payment rule, defined extension grounds, a legal basis for electronic hearings, and further empirical research.
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Pages:78-86
How to cite this article:
Norma Rani Kusumawardhani Zoulba, Budi Ispriyarso "Tax dispute resolution and the principle of justice: A normative juridical analysis of the Indonesian tax court system". International Journal of Law, Vol 12, Issue 4, 2026, Pages 78-86
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