Indonesia (Bali): crypto taxes when leaving Germany
Destination Indonesia (Bali): holding period, tax rate, classification under section 2 AStG, exit taxation and the five scenarios from the year of departure to a return to Germany.
- Leaving Germany does not by itself trigger German tax on crypto held as private assets. It is different for business assets (section 16(3a) EStG) and shares in a company (section 6 AStG). Whether section 2 AStG or the destination country's law then applies depends on the individual case.
- Holding period: None
- Standard rate on crypto gains: Final withholding tax (PPh Pasal 22 Final) on the gross value of each transaction: 0.21 % at an exchange licensed in Indonesia, 1 % at a foreign, unlicensed platform (since 1 August 2025)
- Classification under § 2 AStG: No (burden comparison a good 92 %); the territorial regime for qualified foreign professionals would likely constitute preferential taxation
- Crypto exit tax: No exit taxation for privately held crypto assets is known
At a glance
| Holding period | None |
|---|---|
| Standard rate on crypto gains | Final withholding tax (PPh Pasal 22 Final) on the gross value of each transaction: 0.21 % at an exchange licensed in Indonesia, 1 % at a foreign, unlicensed platform (since 1 August 2025) |
| Classification under § 2 AStG | No (burden comparison a good 92 %); the territorial regime for qualified foreign professionals would likely constitute preferential taxation |
| Crypto exit tax | No exit taxation for privately held crypto assets is known |
| Inheritance tax treaty with Germany | No |
| Registration after the move | NPWP tax number, obligation from KITAS or 183 days; tied to the KITAS process and the 183-day threshold, no shortcut known |
| Tax residency certificate | No shortcut known; tied to the KITAS process and 183 days |
| DAC8/CARF | CARF commitment; reporting, according to available information, starts in 2027 for 2026 data; no official implementing regulation as of 08/2026; no information on DAC8 |
Crypto taxation in Indonesia (Bali)
- Disposal: Withholding tax of 0.21 % or 1 % on the gross value, not the net gain. Licensed exchanges withhold automatically; on foreign platforms, the investor pays. Taxes paid abroad can't be credited against the withholding tax; it applies in full even if the same transaction has already been taxed elsewhere.
- Exchanges and transfers: Crypto-to-crypto exchange is taxable; a transfer between one's own wallets triggers no tax without a change of owner.
- Legal framework and VAT: Since 10 January 2025, the OJK and the central bank supervise; crypto assets count as a financial investment, comparable to securities. PMK 50/2025 (in force since 1 August 2025) therefore drops VAT on the transfer; the trading platform and miners' verification services stay subject to VAT.
- Mining: from tax year 2026, the general income tax schedule instead of the withholding tax (progressive up to 35 % for individuals, 22 % for companies); VAT on the verification service at an effective 2.2 % (previously 1.1 %) on the compensation received, block rewards included; registration as a VAT-liable business.
- Staking, liquidity mining, airdrops: “other income” at market value at receipt, progressive 5 % to 35 %; a later sale is additionally subject to the withholding tax. Hard fork: no express rule; market value at receipt should likely be captured as other income, provided the new tokens have a tradable price.
- Losses and filing: Loss positions can't be offset against gains. Crypto holdings must be declared as an asset in the annual tax return (SPT Tahunan); records must be kept for ten years.
- Wealth and inheritance: no wealth tax, no inheritance or gift tax in the conventional sense.
Classification under § 2 AStG
Indonesia isn't a low-tax country within the meaning of § 2 AStG: at the statutory reference income of €77,000, the progressive schedule, after the personal allowance, produces Indonesian tax of around €19,600 against about €21,200 in Germany, a good 92 %, well above the two-thirds threshold of about €14,100. The withholding tax on crypto transactions attaches to the type of transaction and isn't personal preferential taxation (§ 2(2) no. 2 AStG). The four-year territorial regime for qualified foreign professionals is different: it's open only to foreign nationals, attaches to first-time relocation, and would likely constitute preferential taxation; under Federal Fiscal Court case law, the mere availability of the option is enough.
The five scenarios
Year of departure
- German unlimited tax liability only ends once residence and habitual abode are actually given up.
- Tax residency in Indonesia arises with more than 183 days within twelve months, then retroactively for the entire calendar year. Only a sale in a calendar year where the threshold is demonstrably not reached is safe.
- The visa (e.g., the Second Home Visa from around IDR 2 billion, or a retirement visa) changes nothing; only the actual length of stay matters.
First year after leaving
- Withholding tax of 0.21 % or 1 % on the gross value, regardless of gain or loss. Example: on a sale worth €20,000, a licensed exchange withholds €42; on a foreign platform, €200 would be due, to be remitted by the investor.
- Territorial regime (four years, Indonesian income only): requires qualified employment in a listed specialist field in science, technology, or mathematics, proof of a degree or five years of professional experience, an obligation to transfer knowledge to Indonesian nationals, and tax authority approval. Private crypto investors without such employment aren't eligible. Anyone claiming treaty protection loses the regime retroactively for that year.
- The option to exempt foreign income from Indonesian tax in the first four years of residency is aimed primarily at classic foreign income such as salaries, pensions, or business profits. Whether and to what extent it also affects the crypto withholding tax can't be clearly determined from the available sources; an Indonesian tax advisor should confirm it specifically before emigrating.
More than ten years
- For crypto gains, the regime of the first year continues unchanged.
- If the territorial regime is used, preferential taxation and thus extended limited income tax liability come into consideration on the German side. It ends ten years after the end of the year in which German unlimited tax liability ended; after that, only ordinary limited tax liability remains, requiring a domestic source of income. That's the current position.
- No German-Indonesian inheritance tax treaty: for German nationals, German extended unlimited inheritance tax liability applies if the deceased or donor was fully taxable in Germany within the last five years before the inheritance. After more than ten years, the window is closed.
Moving on to a third country
- No exit taxation for privately held crypto assets; no tax on unrealized crypto gains.
Returning to Germany
- No special Indonesian tax. In Germany, unlimited tax liability returns with the re-establishment of a residence or habitual abode; the original acquisition date counts, and if a position has been held for longer than a year in total, a later sale in Germany is tax-free under § 23 EStG.
The usual advice “sell before emigrating, bring losses along” doesn't fit here: the tax attaches to the gross value of each transaction and doesn't depend on gain or loss. A gain that's tax-free in Germany stays tax-free if sold before emigrating; at 0.21 % or 1 %, though, the benefit is considerably smaller than with a tax on the full gain. Loss positions can't be offset against gains in Indonesia.
Show sources
- Convention between Germany and Indonesia, signed 1990, in force since 1991: double tax treaty
- § 32a EStG: German income tax as the comparison figure in the burden comparison, €21,204
- Art. 7(2) of Minister of Finance Regulation No. 18/PMK.03/2021 with Annex II (catalog of eligible specialist professions): territorial regime for qualified foreign professionals
- Art. 4(1a) of the Indonesian Income Tax Law as amended by the Job Creation Law: basis of the territorial regime
- BFH, judgment of 14 January 2025 – IX R 37/21: preferential taxation; the mere entitlement is sufficient
- UU HPP No. 7/2021: progressive income tax rates as the basis of a rough calculation of our own
- Peraturan Pemerintah No. 49/2024: reorganization of crypto supervision
- Peraturan Menteri Keuangan No. 50/2025 (PMK 50/2025): withholding tax of 0.21 % or 1 %, dropping of VAT on the transfer, final nature of the tax under Art. 22 (Fns. 179, 182)
- Art. 25 and Art. 27 PMK 50/2025 and Art. 17 of the Indonesian Income Tax Law: taxation of mining from tax year 2026, corporate tax rate of 22 %, VAT on verification services
- Art. 28(11) of the Indonesian General Provisions and Tax Procedures Law (KUP): ten-year retention period
Questions about Indonesia (Bali)
Is there a holding period for crypto in Indonesia (Bali)?
How high is the tax on crypto gains in Indonesia (Bali)?
Is Indonesia (Bali) a low-tax country under section 2 AStG?
Does Indonesia (Bali) have an exit tax on crypto?
Legal position: country data 08/2026 (status of the book). Sources are listed in the "Sources" section. The figures are abridged and are not advice on an individual case. The tax law of the destination countries and immigration law are outside our German advisory scope; we coordinate with local advisers. The § 2 AStG classification is our own calculation based on the 2026 tariff and is not an official ruling. Where this English text and the German text differ, the German text prevails.