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Free Practice Questions for USKP Tingkat C

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Key Facts: USKP Tingkat C Exam

4

Subject papers at Tingkat C

PENG-11/KP3SKP/VII/2026

40

Multiple-choice questions per subject

USKP 2026 participant guide

60

Minimum passing score per subject

USKP 2026 participant guide

Rp0

Registration and exam fee

PENG-11/KP3SKP/VII/2026

USKP Tingkat C has four free multiple-choice subject papers of 40 questions each, lasting 2 hours, with a pass mark of 60 per subject. Candidates need a Tingkat B certificate and an S-1 or D-IV degree. These 100 free questions are an independent English-language MCQ study adaptation.

Sample USKP Tingkat C Practice Questions

Try these sample questions to review concepts for the USKP Tingkat C exam. Each question includes a detailed explanation. Start the interactive quiz above for the full 100+ question experience with AI tutoring.

1Under Article 2(5) of the Income Tax Law, which arrangement creates a permanent establishment (BUT) of a foreign company in Indonesia?
A.It keeps a management office and workshop in Jakarta to carry out long-term service contracts in Indonesia
B.It exports goods to Indonesian customers without any people, premises or agents in Indonesia
C.It trades shares on the Indonesia Stock Exchange through an independent licensed broker
D.It licenses standard software to unrelated Indonesian users with no people, premises or equipment in Indonesia
Explanation: Article 2(5) lists places and activities that form a BUT, including a place of management, branch, representative office, factory, workshop and warehouse, construction projects, services by employees for more than 60 days in 12 months, and dependent agents. A management office and workshop used for business in Indonesia clearly qualifies.
2Atlas Corp, a Japanese company, has a BUT in Surabaya that sells industrial generators. Its head office in Japan also sells identical generators directly to a customer in Medan without involving the BUT. Under Article 5(1)(b) of the Income Tax Law, how is the head office's income from this sale treated?
A.It is not taxable in Indonesia, because the contract was signed abroad
B.It is attributed to the BUT and included in the BUT's taxable income
C.The customer withholds 20% PPh 26, which settles all tax on it
D.Only import PPN applies to it
Explanation: Under the force of attraction rule in Article 5(1)(b), income of the head office from selling goods in Indonesia of the same kind as those sold by its BUT is attributed to the BUT. It is taxed as part of the BUT's income, subject to any limits in an applicable tax treaty.
3Under Article 5(3) of the Income Tax Law, which payment by a BUT to its own head office cannot be deducted?
A.Salaries of engineers working at the BUT's project site
B.Freight paid to an unrelated carrier for materials delivered to the BUT
C.Audit fees paid to a local public accounting firm for the BUT's accounts
D.Royalties, management or technical service fees, or interest paid to the head office, other than interest in banking business
Explanation: A BUT and its head office are one legal entity, so payments by the BUT to the head office for royalties or the use of property, management and other service fees, and interest (except in banking business) are not deductible. Costs the BUT pays to third parties to earn its income are deductible under the normal rules.
4Under Article 5(1) of the Income Tax Law, which income of a foreign company with a BUT in Indonesia is not attributed to the BUT?
A.Income from the BUT's own business and from assets it owns or controls
B.Income from services performed in Indonesia by the head office of the same kind as the BUT's services
C.Dividends the head office receives from an unrelated company in Singapore
D.Income from head office sales in Indonesia of goods of the same kind as the BUT sells
Explanation: Article 5(1) attributes to a BUT its own business income and income from assets it owns or controls, plus head office income from sales, services or other business in Indonesia of the same kind as the BUT's. Dividends the head office earns from an unrelated foreign company have no connection with Indonesia or the BUT.
5Under Article 2(5)(n) of the Income Tax Law, when does an agent acting in Indonesia for a foreign company create a BUT?
A.When the agent is an Indonesian citizen with a trade licence
B.When the agent represents many unrelated suppliers
C.When the agent's commissions are subject to PPh 23
D.When the agent's position is not independent, for example acting almost only for the foreign company and concluding contracts in its name
Explanation: An agent whose position is not independent creates a BUT for the foreign company. Signs of dependence include acting wholly or almost wholly for one principal, following its detailed instructions, habitually concluding contracts in its name and bearing no business risk of its own.
6PT Andalas plans to merge with a group company using book value rather than market value. Under PMK 52/PMK.010/2017, as amended, what is required?
A.Approval from the Director General of Taxes, with the merger passing the business purpose test
B.An unaudited balance sheet and a bank guarantee
C.Listing at least 20% of the merged company's shares on the stock exchange
D.Converting all debts into preference shares within 30 days
Explanation: Mergers, consolidations and business expansions using book value need approval from the Director General of Taxes, and the restructuring must pass the business purpose test, showing genuine commercial reasons rather than tax avoidance. Otherwise, assets are transferred at market value under Article 10 of the Income Tax Law.
7PT Bintang merges into PT Samudra using book value approved under PMK 52/PMK.010/2017. PT Bintang has Rp3,000,000,000 of unused tax losses. What happens to these losses?
A.PT Samudra can offset them over PT Bintang's remaining carry-forward period
B.PT Samudra can offset them over a new 5-year period
C.PT Samudra cannot offset them
D.They are refunded to PT Bintang's shareholders
Explanation: In a merger using book value, the tax losses of the company that merges in cannot be carried over and offset by the receiving company. This stops mergers being used to acquire tax losses.
8An oil and gas contractor's production sharing contract fixes corporate income tax at 30% and branch profits tax at 20% of after-tax profit. What is the combined effective rate on taxable profit?
A.50%
B.44%
C.36%
D.30%
Explanation: On taxable profit of 100, corporate income tax is 30, leaving 70. Branch profits tax is 20% × 70 = 14. The combined tax is 44, or 44% of taxable profit. Under the lex specialis principle, rates fixed in a contract continue to apply to that contract.
9Under Article 12 of PP 94 of 2010, when is an interest-free loan from a shareholder to a limited liability company accepted for tax purposes?
A.Whenever the loan agreement is notarised
B.When the borrowing company is listed on the stock exchange
C.When the loan is repaid within 12 months
D.When the funds are the shareholder's own, the company's capital is fully paid up, the shareholder is not in a loss position, and the company is in financial difficulty
Explanation: An interest-free shareholder loan is accepted if the funds come from the shareholder's own resources rather than third-party borrowing, the company's share capital has been fully paid up, the shareholder is not making a loss, and the company is in financial difficulty and needs the loan to survive. If these conditions are not met, the loan is treated as bearing a reasonable rate of interest.
10PT Surya converts Rp20,000,000,000 of convertible bonds into shares with a nominal value of Rp12,000,000,000 and records Rp8,000,000,000 as share premium (agio). How is the conversion treated for PT Surya's corporate income tax?
A.The Rp8,000,000,000 is taxable income from debt forgiveness
B.The whole Rp20,000,000,000 is subject to 20% final tax
C.It is an exchange of debt for shares, so the share premium is not taxable income
D.PT Surya must pay 10% final tax on the share premium
Explanation: Amounts a company receives in exchange for shares, including share premium, are excluded from income tax objects under Article 4(3)(c) of the Income Tax Law. Settling bonds by issuing shares at the carrying amount of the debt does not create income for the company.

About the USKP Tingkat C Exam

USKP Tingkat C is the highest level of Indonesia's tax consultant certification exam, run by the Panitia Penyelenggara Sertifikasi Konsultan Pajak formed by the Minister of Finance. Its four subjects cover corporate income tax, international taxation, withholding taxes and tax accounting, with a strong focus on permanent establishments, tax treaties and transfer pricing. Candidates need a Tingkat B certificate. This free bank is an independent English-language MCQ study adaptation, not an official translation or simulation of the Indonesian exam.

Exam sponsor: Panitia Penyelenggara Sertifikasi Konsultan Pajak (PPSKP), through its Executive Committee (KP3SKP). The requirements and fees below concern the certification or admission exam, separate from our free practice resources.

Assessment

Four separate multiple-choice subject papers of 40 questions each, each lasting 2 hours: PPh Badan and SPT PPh Badan, Pajak Internasional, PPh Pot/Put and Akuntansi Perpajakan. A score of at least 60 passes a subject. Candidates who pass some subjects resit only the rest in later periods.

Time Limit

2 hours per subject

Passing Score

60 per subject

Exam / Certification Fees

Free

Exam sponsor website

Fees, eligibility, and exam policies can change. Confirm them with the exam sponsor before applying or paying.

Our practice resources: topics covered

We aim to reflect publicly available exam outlines and topic information in our study resources. Coverage, format, and difficulty may differ from the actual exam, and we cannot guarantee that every detail is accurate or current. Confirm exam requirements, fees, and policies with the official exam sponsor.

25 of 100 questions

PPh Badan dan SPT PPh Badan

BUT definition, force of attraction and head office payments, dependent agents, book-value mergers and tax losses, oil and gas contract rates, shareholder loans, capital transactions, liquidation and debt forgiveness, asset transfers at market value, joint cost allocation, controlled foreign companies, thin capitalisation, related-party receivables and foreign losses.

25 of 100 questions

Pajak Internasional

Service and construction PEs under treaties, preparatory activities, treaty benefits and beneficial ownership under PMK 112 of 2025, the principal purpose test, treaty shopping, foreign tax credits, special relationships, transfer pricing methods and documentation, intangibles, APAs, MAP, secondary adjustments and the global minimum tax.

25 of 100 questions

PPh Pemotongan/Pemungutan

Branch profits tax and reinvestment, BUT withholding, indirect share transfers, treaty abuse and DGT forms, treaty rates on dividends and interest, business profits, international transport, bonds and deposits, property sales by non-residents, and treaty articles on share gains, directors' fees, entertainers, pensions and professional services.

25 of 100 questions

Akuntansi Perpajakan

Deferred tax in business combinations, impairment, borrowing costs, revenue recognition, investments in subsidiaries, goodwill, tax losses, offsetting and presentation, other comprehensive income, uncertain tax treatments, leases, consolidation eliminations, effective tax rates, rate changes, interim reporting, prior-period tax adjustments, biological assets and withholding on dividends.

Preparing for the USKP Tingkat C Exam

What You Need to Know

  • Passing score: 60 per subject
  • Assessment: Four separate multiple-choice subject papers of 40 questions each, each lasting 2 hours: PPh Badan and SPT PPh Badan, Pajak Internasional, PPh Pot/Put and Akuntansi Perpajakan. A score of at least 60 passes a subject. Candidates who pass some subjects resit only the rest in later periods.
  • Time limit: 2 hours per subject
  • Exam / certification fees: Free Official sources

Using Our Practice Resources

  • Work through all 100 available questions
  • Review every answer and explanation
  • Track weak areas and revisit them
  • Use our AI tutor for tough concepts

USKP Tingkat C: Suggested Study Strategy

1Pace each paper: 40 questions in 2 hours leaves 3 minutes per question, so practise branch profits tax, transfer pricing and deferred tax calculations under time pressure.
2For each cross-border payment, first decide whether the recipient has a BUT, then apply domestic PPh 26 and check whether a treaty article and a valid DGT form reduce or remove the tax.
3Learn the current regulations: PMK 172 of 2023 on transfer pricing, PMK 112 of 2025 on tax treaties and PMK 136 of 2024 on the global minimum tax.
4For deferred tax, compare each carrying amount with its tax base, then check the exceptions for goodwill, subsidiaries and final-taxed income.

Frequently Asked Questions

What is USKP Tingkat C?

It is the highest level of Indonesia's tax consultant certification exam. It follows Tingkat B and adds international taxation, including permanent establishments, tax treaties and transfer pricing.

What is the exam format and pass mark?

There are four separate subject papers, each with 40 multiple-choice questions worth 2.5 points apiece and lasting 2 hours. The pass mark is 60 in each subject.

How much does USKP Tingkat C cost?

Nothing. The 2026 KP3SKP announcements state that the exam is free.

Who can register for USKP Tingkat C?

Candidates need a Tingkat B tax consultant certificate, an S-1 or D-IV degree in any field from an accredited institution or official college, an Indonesian identity card and a stamped participant statement. Check each period's announcement, as the 2026 periods were for repeat candidates.

Are these official USKP exam questions?

No. This is independent English-language multiple-choice practice by OpenExamPrep. It is not an official translation of PPSKP materials, does not simulate the Indonesian exam, and is not affiliated with or endorsed by PPSKP, the Ministry of Finance or any tax consultant association.