AOW, pension and tax in Indonesia: article 19 is the lesson
The pension article sits at number 19 in this treaty, and it works the other way round from southern Europe: the Netherlands may keep taxing AOW, pension and annuity, and Indonesia gives a credit. The four-year expat scheme doesn't apply to retirees and doesn't combine with the treaty, the accrued AOW does travel with you in full, and the protective assessment gets no automatic deferral outside the EU.
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Written and checked by Auke on , against the sources at the bottom. Is something no longer right? Report it below and I'll fix it.
If you live in Indonesia, the Netherlands may keep taxing your AOW, your pension and your annuity. On Bali forums you read that you pay "almost no tax" there, but that is half the story.
Three things to know up front:
- It is in article 19 of the tax treaty between the Netherlands and Indonesia, at an article number where you wouldn't look for it. Indonesia credits the Dutch tax against its own levy: what you pay in the Netherlands is deducted from the Indonesian tax on that income.
- A pension counts as Dutch as long as the premiums were tax-facilitated in the Netherlands, meaning they were paid with a tax advantage. That stays so if you transfer it to a foreign fund. This is in the fourth paragraph.
- Forums ascribe an Indonesian scheme to everyone, but it doesn't exist for retirees.
What exactly does article 19 say?
| Income | Who may tax according to the treaty |
|---|---|
| Occupational pension and annuity from the Netherlands | the Netherlands may tax (article 19, paragraph 1) |
| AOW and other social security benefits | the Netherlands may tax (article 19, paragraph 2) |
| Pension from government service, such as ABP | the Netherlands may tax (article 20) |
| When a pension "comes from the Netherlands" | if the premiums or entitlements were tax-facilitated in the Netherlands (article 19, paragraph 4) |
"May be taxed" means that Indonesia as the country of residence may also include your income in its base. Article 24 stands against that: for income the Netherlands may tax under the treaty, Indonesia credits the Dutch tax against the Indonesian tax, up to at most the part of the Indonesian tax attributable to that income.
For the government pension there is an exception in article 20, paragraph 3: the Netherlands' right lapses if the services were rendered by someone who is both a resident and a national of Indonesia. For a Dutch national that doesn't apply.
When are you liable to tax in Indonesia?
The Indonesian tax authority regards a foreigner as a resident taxpayer, so as a resident for tax purposes, in two cases:
- they are in Indonesia for more than 183 days within twelve months, not necessarily consecutively;
- they are in Indonesia in a tax year with the intention of living there.
An ITAS, a KITAP (both residence permits) or a rental contract counts as proof of that intention.
A resident taxpayer is in principle taxed on their income from inside and outside Indonesia. They need a tax number (NPWP) and file annually. The return for 2024 had to be in by 31 March 2025 at the latest. How you get that number is in SKTT and NPWP in Indonesia.
Does the four-year expat scheme apply to you?
In principle not. Since the Cipta Kerja law Indonesia taxes a foreign resident taxpayer, under conditions, only on income from Indonesia. That applies for four tax years, from the moment they became a resident taxpayer.
Regulation PMK 18/2021 gives that treatment only to those with certain expertise. That means:
- a position on a list of 25 types;
- knowledge of science, technology or mathematics, with a certificate;
- at least five years of work experience;
- the duty to transfer that knowledge.
You apply for it at your tax office, which decides within ten working days.
And the most important detail for a Dutch national: the scheme does not apply if you make use of the tax treaty. You choose one or the other. A retiree with a Dutch pension moreover doesn't fit the list of positions.
Don't count on the expat scheme that circulates on forums. It is written for foreign experts in employment, runs for four years, and excludes the treaty. For a retiree the ordinary route of the treaty is the only one that counts: the Netherlands may tax, Indonesia gives a credit.
Does the accrued AOW go along in full?
Yes. Indonesia is on the list of countries with which the Netherlands has a social security agreement. To those countries the Netherlands exports the full AOW, so including the single person's rate of 70 per cent of the minimum wage. To countries without such a treaty only the rate for married people goes along. Accrual does stop on your departure date: every year you are not insured, you later get 2 per cent less AOW, unless you insure voluntarily with the SVB within a year. More on that in your AOW accrual stops on departure.
What else does the Netherlands not let go of?
For the year of departure you file an M return, the tax return for the year in which you emigrate.
If you built up pension or annuity in the Netherlands with a tax advantage, or hold a substantial interest, a protective assessment follows. You don't have to pay that assessment for up to ten years, as long as you follow the rules. After that you can ask for remission for pension and annuity. For a substantial interest the assessment stays valid indefinitely. If you emigrate to an EU or EEA country, you automatically get deferral of payment. For Indonesia you don't: then you apply for it yourself, as stated on the assessment.
The sum you make before leaving: calculate your net monthly income with continuing Dutch tax, and put the Indonesian costs next to it. With this list you know exactly what to ask a tax adviser.
In Vertrekklaar this is phase 3 of 5 of the journey, step 3.2: the same steps, but for your situation — in your order, tickable, and with the deadlines watched. See the whole journey to Indonesia or go straight to step 3.2 in the open plan.
What this means for your numbers →
What this rests on
The facts in this article come from these official pages. Rules change. When in doubt, go by the source, not this article.
- Tax treaty Netherlands-Indonesia — article 19 (pensions, annuities, social security), 20 (government) and 24 (double taxation) — wetten.overheid.nl
- Directorate General of Taxes — tax liability and filing for foreigners — pajak.go.id
- Answer to parliamentary questions — the countries to which the full AOW is exported — zoek.officielebekendmakingen.nl
- Tax Administration — protective assessment on emigration — belastingdienst.nl
- Directorate General of Taxes — the four-year scheme for foreigners with certain expertise (PMK 18/2021) — pajak.go.id
- SVB — voluntary AOW and Anw insurance on departure — svb.nl
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