“The company isn’t immune. So it’s not like a tax amnesty. This isn’t a free pass.” Indonesian Finance Minister Purbaya Yudhi Sadewa used those words on Tuesday, June 23, 2026, to describe the legal shield attached to Danantara’s new Patriot Bonds and Red and White Bonds.
His point was narrow. The protection covers the money put into the bonds, not the person’s other assets or businesses. “The correct understanding is that the funds used to purchase Patriot Bonds will not be subject to scrutiny regarding their origin,” he told reporters in Jakarta. “However, if the owner has other businesses, those can still be pursued.”
What the law says
The bonds come from Law Number 4 of 2026, which amends the 2023 law on development and strengthening of the financial sector (P2SK). It was promulgated on June 17, 2026. It lets the Danantara Investment Management Agency issue special debt securities, the Patriot Bond and the Merah Putih (Red and White) Bond.
Article 50A is the clause drawing attention. It has the state protect buyers of the instruments in the primary market from general criminal prosecution, special criminal offenses including tax crimes, and civil lawsuits. Transaction data cannot be used as a basis for taxation or as court evidence. The law also widens the pool of eligible investors to include taxpayers who took part in the earlier tax amnesty and the Voluntary Disclosure Program (PPS).
That last part fed a perception that the bonds could serve as a follow-on channel for participants in both programs, and critics have called the scheme a concealed tax amnesty. The government rejects that label.
The minister’s defense
Purbaya said the money is treated as investment funds, not as the object of an inquiry into where it came from. Asked whether the rules open the door to money laundering, he brushed the claim aside and said the aim is to draw funds into the domestic financial system.
“Rather than keeping the money outside, let it flow into the system,” he said. “Yes, there will be a small loss. But the money will flow into our economy, and we can use it for development.” He also set a clock for would-be buyers: “If you have a lot of money, get in there quickly. I’ll give you six months.”
Other fiscal steps, including possible changes to excise policy and management of public funds, are still under internal government discussion and have not gone to the DPR, he said.
Skeptics
Fajry Akbar, head of research at the Center of Indonesia Taxation Analysis (CITA), told Kompas the P2SK provisions could weaken the credibility of tax compliance policy. “If the end result is merely purchasing bonds and being considered compliant, this could undermine the credibility of tax compliance,” he said.
Media Wahyudi Askar, director of public policy at the Center of Economic and Law Studies (Celios), argued for an enforcement phase using data from the earlier amnesty. “Otherwise, this is just an amnesty without enforcement,” he said.
Past results give some context. Kompas noted that the 2016 Tax Amnesty drew declarations of overseas assets worth Rp 1,031 trillion, yet only Rp 147 trillion was repatriated. For the PPS, the tax authorities have not released a repatriation figure, only combined declarations of Rp 512.58 trillion.
Coordinating Minister for Economic Affairs Airlangga Hartarto gave little away. “We’ll discuss it later when it is announced, as it is included in the P2SK Law,” he said. Inge Diana Rismawanti of the Directorate General of Taxes said her office is still studying the provisions and is “unable to provide further comments at this time.”
Sources
- Investor Fund Protection Guarantees in Danantara Bonds Draw Attention
- Protection for Patriot bond investors only applies to funds: Minister
