KEK Sanur Tax Incentives: Fiscal and Non-Fiscal Facilities Explained

KEK Sanur tax incentives are the specific fiscal and non-fiscal facilities that qualifying investors can obtain for projects located in the Sanur Health Special Economic Zone in Bali. These incentives sit under Indonesia’s national KEK regime (primarily PP 96/2015 as updated by PP 40/2021) and are applied through sector‑ and investment‑size‑based rules, not automatically.

What “tax incentives” mean in KEK Sanur

In Indonesian law, KEK Sanur is a Kawasan Ekonomi Khusus (Special Economic Zone) focused on health, wellness, MICE and supporting services. The “kek sanur tax facilities” you read about are not a single certificate, but a stack of potential facilities that may apply if:

• Your business is a licensed KEK business entity or business actor in KEK Sanur (Badan Usaha / Pelaku Usaha KEK); and
• Your investment size, sector, and planned activities fall within what current regulations define as “pioneer” or “priority” for SEZ incentives.

Core legal bases for KEK Sanur fiscal and non-fiscal facilities (as of June 2026) include:

• Law 39/2009 on Special Economic Zones (UU KEK)
• Government Regulation 96/2015 as updated by PP 40/2021 on KEK facilities
• Derivative Ministry of Finance and sectoral regulations (latest PMK and implementing rules must always be re‑checked).

KEK Sanur is established by PP 41/2022. The detailed fiscal package follows the general KEK framework; sectoral nuances for health services and medical tourism are being refined as implementing rules evolve. Eligibility remains case‑by‑case.

Headline: What KEK Sanur fiscal incentives can include

At a high level, current KEK regulations allow for:

• Corporate income tax (CIT) reduction / “tax holiday Sanur SEZ” — 20–100% reduction during a fixed incentive period, tiered by investment size and sector.
• Import duty and tax facilities — exemptions or relief on import duty for capital goods/raw materials used in KEK, plus not‐collected VAT (PPN) and Article 22 import tax on qualifying imports.
• Domestic VAT facilities — “PPN tidak dipungut” (not collected) on certain transactions inside KEK or between KEK and other specified zones.
• Regional tax and retribution reductions — up to 50–100% reduction by local regulation for eligible KEK investors.

Non-fiscal facilities include one‑stop OSS licensing, longer foreign manpower plans (RPTKA up to 5 years), and immigration conveniences for foreign experts and medical professionals.

All numbers below are regulation‑based ranges for Indonesia’s KEK regime, not a guarantee that a specific KEK Sanur project will qualify. Final treatment depends on current PMK (Peraturan Menteri Keuangan) and technical approvals.

Corporate income tax facilities in KEK Sanur

Tax holiday tiers: concept and ranges

Under the KEK framework, qualifying KEK business actors can receive a significant corporate income tax reduction (commonly called a “tax holiday”) for a set period. Core parameters:

• Reduction level: typically 20% up to 100% of payable CIT on qualifying income.
• Incentive period: fixed term (for example 5–20 years in the broader KEK/tax holiday regime), then followed by a transition period with a partial reduction (e.g. 50%).
• Tiers by investment size: larger committed investment generally opens access to longer periods and higher reduction percentages.
• Sector and activity filters: only certain “pioneer” or “priority” sectors in a KEK can qualify (for KEK Sanur this centers on health, medical, wellness, life sciences, supporting tourism, education and R&D, subject to official lists).

The actual thresholds (e.g. IDR amounts per tier, eligible KBLI codes) are set in the latest Ministry of Finance regulation on tax holidays and KEK facilities. These are updated periodically; you must check the current PMK and not rely on older numbers.

Key conditions commonly applied

Common conditions in KEK tax holiday schemes (details for KEK Sanur projects must be checked against the live rules):

• Minimum new investment in fixed assets (in certain PMKs this has started from tens or hundreds of billions of rupiah for the lowest tier, rising for longer holidays).
• New taxpayer status or major expansion, not purely relocation of an existing business to KEK Sanur.
• Compliance history: no significant outstanding tax disputes or criminal tax cases.
• Reporting obligations: periodic investment and operational reporting to BKPM/OSS and the KEK Administrator.

The facility typically applies only to income generated from the approved KEK‑based project. Non‑qualifying activities or income streams can remain fully taxable at the normal rate.

How this interacts with general tax holidays

Indonesia also offers national tax holidays outside KEK. For some sectors, KEK investors can either:

• Use a KEK‑specific facility, or
• Apply a general tax holiday/tax allowance scheme, depending on which is more advantageous and legally allowed.

Double counting on the same income stream is generally not permitted. Structuring and choice of facility requires tax‑professional advice. KEK Sanur Intelligence explains the framework; we do not provide legal opinions or guarantee approvals.

VAT (PPN) and sales‑tax facilities

PPN “not collected” (PPN tidak dipungut)

KEK regulations allow for PPN tidak dipungut (VAT not collected) on specific transactions related to KEK activities. In practice, this can include:

• Imports of capital goods and certain raw materials into KEK for approved operations.
• Delivery of taxable goods from the rest of Indonesia into KEK in certain cases.
• Transactions within KEK where both parties are KEK‑registered and the goods/services are directly related to the approved KEK business activity.

This is not a blanket exemption: it is a treatment applied under explicit rules. Documentation, correct invoicing, and proof that the goods are used in KEK activities are essential to actually benefit from “PPN tidak dipungut.”

Luxury-goods sales tax (PPnBM)

The KEK framework allows specific PPnBM relief on qualifying goods used for production in KEK or re‑export. Application in KEK Sanur will particularly matter for high‑value medical equipment and certain wellness assets.

As usual, treatment depends on HS code classification and end use. Up‑to‑date confirmation from customs and tax authorities is needed before you model any PPnBM relief into your financial projections.

Import‑duty and customs facilities

KEK status is designed to support capital‑intensive investment. For KEK Sanur, that includes hospitals, clinics, labs, rehabilitation, wellness resorts, and supporting infrastructure.Areas where import facilities may apply:

• Capital goods and equipment for construction and operation of hospitals, labs, wellness facilities, hotels, and supporting infrastructure inside KEK Sanur.
• Raw materials and components directly used in production or services inside KEK (e.g. certain medical consumables or devices, subject to rules).
• Re‑export‑oriented activities (for example certain medical device assembly or R&D‑linked manufacturing, if approved).

Main types of customs/tax facilities:

• Import duty exemption (pembebasan bea masuk) for qualifying imports used in KEK production/service.
• Not collected VAT and Article 22 import income tax on specific imports under KEK facilities.
• Possible use of bonded‑zone‑like arrangements for storage and inward processing linked to KEK status, depending on the detailed implementing rules and operator setup.

For investors, this can materially shift cash‑flow timing on large equipment imports. However, any breach of usage rules (e.g. diverting duty‑exempt goods for non‑KEK use) can trigger back‑taxes, penalties, and revocation of facilities.

Regional (local) tax and retribution reductions

KEK investors can receive reductions on certain provincial and regency/municipal taxes and retributions, such as:

• Hotel and restaurant tax
• Entertainment tax
• Advertisement tax
• Certain licensing‑related retributions under local regulations

KEK regulations allow local governments to grant 50–100% reductions for a specified period to support KEK development. For KEK Sanur, details are implemented through Bali Provincial and Denpasar City regulations aligned with PP 41/2022.

Key points:

• Reductions are not automatic; they depend on local Perda/Perwali and agreements with the KEK Administrator.
• The scope (which taxes, for how long, at what percentage reduction) can differ by type of activity (e.g. health services, hospitality, MICE support).
• Policy can evolve — reductions granted to early investors might not be identical for later entrants.

Any financial model should scenario‑test regional taxes at both full statutory rates and with only partial reductions.

Other national tax facilities linked to KEK

Beyond headline CIT, VAT, and customs, KEK investors may access additional facilities under the broader KEK/tax‑incentive regime, subject to separate eligibility tests:

• Tax allowance (fasilitas pengurangan penghasilan bruto / PPh Badan) for certain investments that do not qualify for tax holidays but meet sector and scale requirements.
• Accelerated depreciation and amortisation for fixed assets in qualifying activities inside KEK.
• Reduced withholding tax rates on dividends to foreign shareholders when combined with treaty benefits (subject to DGT forms and beneficial‑ownership tests).
• R&D super‑deductions for eligible research and vocational training activities located in or serving KEK activities.

These are governed by separate PMKs (for example the R&D super‑deduction regime) and may be layered with KEK facilities only to the extent expressly allowed by regulation. Overlapping facilities must be evaluated carefully to avoid disallowed double benefits.

Non‑fiscal facilities for KEK Sanur investors

KEK Sanur is not only about tax. For many healthcare and wellness investors, non‑fiscal facilities are equally important.

OSS‑based one‑stop licensing

KEK Sanur uses the national OSS-RBA (Online Single Submission – Risk Based Approach) system, with a KEK Administrator acting as the local facilitator. The intention:

• Centralise business‑licensing processes within KEK Sanur.
• Shorten timelines for NIB (Business Identification Number), sectoral licenses (healthcare, hospitality, education, etc.), and KEK‑specific status.
• Integrate building approvals, environmental approvals, and operational permits into an OSS‑linked workflow.

In practice, timelines and administrative quality depend on:

• Completeness of your submissions (corporate documents, feasibility studies, technical plans).
• Alignment with KEK Sanur’s spatial plan and sector focus.
• Coordination between the KEK Administrator, BKPM/investment authorities, and sectoral ministries.

The “one‑stop” promise does not remove compliance obligations; it centralises them. Investors still need competent local counsel or project managers to actually deliver the required documentation.

Immigration facilities and foreign talent

Health and wellness SEZs need international expertise. KEK regulations generally enable:

• Facilitated work permits (RPTKA) and immigration channels for foreign experts assigned to KEK businesses.
• Longer RPTKA validity: for certain KEK positions, RPTKA can be approved for up to 5 years, compared with shorter periods in non‑KEK areas.
• Support for multiple entry or long‑term visas for investors, directors, and key medical professionals associated with KEK projects, subject to immigration regulations.

All foreign‑manpower rules, including ratios, localisation plans, and training obligations, still apply. KEK status can make the process more predictable and centralised; it does not waive national labour law.

Land, HPL and HGB structures (briefly)

KEK Sanur is developed on land held under HPL (Hak Pengelolaan Lahan) by the KEK’s managing entity. Investors typically do not receive HPL themselves; instead they obtain:

• HGB (Hak Guna Bangunan) over HPL – a building‑use right granted over the KEK’s HPL parcel, often for up to 30 years initially, extendable.
• Lease or cooperation agreements linked to that HGB over HPL structure.

Land rights are not a tax incentive but they are a critical input to any decision to pursue KEK Sanur facilities. Security of tenure, alignment between your HGB term and tax‑holiday period, and step‑in rights for lenders must be carefully documented.

Mid‑project structuring is expensive. If you are considering KEK Sanur and want to align land structure, tax facilities, and licensing from the outset, you can plan your trip and coordinate a site and adviser visit via email or WhatsApp with our team.

How KEK Sanur incentives differ from “generic” KEK tax incentives

The legal backbone is national and shared across KEKs, but KEK Sanur has a specific health‑and‑wellness mandate under PP 41/2022. Some implications:

• Sector priority: healthcare, wellness, supporting hospitality, MICE, and related education/R&D are central; heavy industry is not.
• Regulatory stack: KEK rules layer with Ministry of Health and related sectoral rules for hospitals, clinics, telemedicine, and medical devices.
• Operational intensity: many KEK Sanur projects are service‑intensive rather than export manufacturing – this can affect how customs/VAT facilities are practically used.

Policy makers may calibrate incentive generosity and selection criteria differently in KEK Sanur compared to industrial KEKs. You cannot safely assume that an incentive that applied in a manufacturing KEK will operate identically for a health‑tourism project in Sanur.

Summary table: KEK Sanur fiscal & non‑fiscal facilities

Facility type	Example benefit	Key conditions (indicative)	Who decides
Corporate income tax reduction (“tax holiday Sanur SEZ”)	20–100% CIT reduction for a fixed period on qualifying KEK income	Minimum investment size; qualifying sector & KBLI; KEK business status; current PMK compliance	Ministry of Finance / DGT based on KEK & BKPM inputs
Import duty exemption	0% duty on qualifying capital goods/raw materials used in KEK	Goods imported to and used in KEK; customs approval; reporting and inventory control	Customs (DJBC) under KEK rules
VAT & Article 22 import tax not collected	Cash‑flow relief for KEK‑bound imports and selected domestic supplies	Correct documentation; goods directly used in KEK activities; adherence to PPN tidak dipungut rules	DGT & customs under tax law and KEK regulations
Regional tax/retribution reduction	50–100% reduction of certain local taxes for a defined period	Local regulations (Perda/Perwali); KEK project status; compliance with reporting	Bali Province & Denpasar City governments
Accelerated depreciation / tax allowance	Faster expense recognition, lower taxable income in early years	Eligible sector and assets; election between facilities where required	Ministry of Finance via DGT
One‑stop OSS licensing	Centralised processing of NIB and sectoral licenses inside KEK	Complete documentation; alignment with KEK Sanur’s spatial and sector plan	OSS system; KEK Administrator; BKPM; sectoral ministries
RPTKA up to 5 years	Longer‑term work‑plan approval for foreign experts	KEK business status; compliant employment contracts; training/localisation plans	Ministry of Manpower, coordinated with KEK Administrator
Facilitated visas & stay permits	Smoother entry and stay for investors and key foreign staff	Documentation; security/immigration clearance; alignment with KEK project	Directorate General of Immigration

Minimum investment and sector thresholds: why they matter

The most common misconception around insentif KEK Sanur is that any business physically located in KEK Sanur automatically receives all listed incentives. That is not how the system works.

Key gating factors usually include:

• Investment value (nilai investasi) – CIT holidays and some customs/VAT facilities are linked to total capital expenditure committed and realised in the KEK project.
• Sector classification – your KBLI (Indonesian business classification code) and actual activities must sit in the list of sectors eligible for KEK facilities in the relevant PMK and sectoral regulations.
• Business scale and role – anchor hospitals or integrated wellness operators will be assessed differently from small service providers operating inside KEK.

The underlying regulations are public (see pajak.go.id and kek.go.id), but they are dense and cross‑referenced. Any serious investor should:

1. Map their intended activities to KBLI codes and KEK‑eligible sectors.
2. Estimate total investment value (CAPEX and working capital) by phase.
3. Check which facilities theoretically attach to that combination under current PMK and KEK rules.

Our role at KEK Sanur Intelligence is explanatory and analytical. We can help you frame the questions and outline the process. We cannot issue binding views on eligibility – that sits with the authorities and, ultimately, with formal tax/legal advisers.

Process overview: from PT PMA to KEK incentives

For foreign investors, the path to any KEK Sanur fiscal facility typically runs through these steps:

1. Incorporate the investment vehicle (often a PT PMA)

Most international investors use a PT PMA (foreign investment limited liability company) as the operating entity:

• Incorporation under Indonesian Company Law, with foreign shareholding within the allowed limits for your sector.
• Capitalisation at levels consistent with your projected KEK investment and any minimum capital rules.

2. Obtain NIB and core licenses via OSS-RBA

Use the OSS system to obtain:

• NIB (Business Identification Number) and base business license.
• Sectoral licenses (e.g. health‑facility operation permits, hotel licenses) depending on your project profile.

3. Secure KEK Sanur project status and land rights

You will need:

• A cooperation framework with the KEK Sanur business entity / land‑holding entity.
• Formal allocation of space and, where relevant, HGB over HPL or a lease agreement spanning your planned investment period.

4. Apply for KEK‑linked fiscal facilities

Once you have a defined project inside KEK Sanur:

• Confirm which KEK facilities you intend to apply for (CIT reduction, customs facilities, etc.).
• Submit the required applications to the relevant authorities (DGT/Ministry of Finance for tax, Customs for import facilities, local government for regional tax relief), usually with support/endorsement from the KEK Administrator.
• Be prepared for questions on business plans, investment timelines, employment, and projected financials.

All applications are case‑by‑case. Approval, partial approval, or rejection is a discretionary administrative outcome, not a right.

Risk, change and how to model KEK Sanur incentives

Two realities every serious investor should internalise:

• Regulations change. Tax, customs, and KEK rules are amended regularly. A facility available in 2024 may be tightened or reshaped by 2026.
• Practice differs from paper. Even with strong regulations, administrative practice (processing times, interpretation, evidence demands) can differ across regions and projects.

For serious capital allocation, that implies:

• Build financial models that can still survive with reduced or delayed incentives.
• Treat KEK Sanur fiscal facilities as an upside scenario, not as the sole basis for viability.
• Include regulatory‑change risk in board papers and investor memos.

For latest official references:

• pajak.go.id – official Directorate General of Taxes site.
• kek.go.id – official KEK National Council information.

If you want structured help translating those regulations into a KEK Sanur‑specific roadmap, you can plan your trip and request a focused workshop via email or WhatsApp with our network of advisors.

FAQs on KEK Sanur tax incentives

Do all companies in KEK Sanur automatically get tax holidays?

No. Being physically located in KEK Sanur does not automatically grant a tax holiday. Corporate income tax reductions are granted only if your project meets specific investment-size, sector, and regulatory criteria under current Ministry of Finance rules, and your application is approved.

What investment amount is needed to qualify for a KEK Sanur tax holiday?

There is no single fixed number for all time. Minimum investment thresholds are set in the latest tax-holiday and KEK-related regulations and can change. They are usually in the tens to hundreds of billions of rupiah for meaningful holidays, but you must confirm the live PMK and seek professional advice before using any number in your financial model.

Are medical and wellness projects treated as “pioneer” sectors in KEK Sanur?

KEK Sanur is thematically focused on health, medical tourism, wellness, and supporting services. That makes such projects natural candidates, but “pioneer” or “priority” status depends on how your specific activities and KBLI codes line up with the official sector lists in force at the time of application.

Can I combine KEK Sanur incentives with other Indonesian tax facilities?

Sometimes, but not always. Certain facilities cannot be layered on the same income (for example, you generally cannot double-count a standard tax holiday and a KEK-specific holiday on the same project). The permissibility of combining incentives must be checked against current regulations and usually requires professional tax advice.

Who decides if my KEK Sanur project is eligible for fiscal incentives?

Eligibility is determined by the competent authorities: primarily the Ministry of Finance (through the Directorate General of Taxes and Customs), local governments for regional taxes, and the KEK Administrator for zone status. KEK Sanur Intelligence provides independent analysis, but no one can pay to change what we publish; if you proceed with our partner they may pay us a referral fee at no extra cost to you.