How the Money Flows

Four scenarios showing why the structure matters — and where things are heading.

01 Proposed Structure
🌏 International
🇮🇩 Indonesia
Guest
books in EUR/USD/etc
pays
Airbnb
pays out
Bali 5 Star
Australia 🇦🇺
Owner's Share
stays offshore
Owner 🇦🇺
Operational funds
+ management fee
sent to Indonesia
Bali 5 Star
Indonesia 🇮🇩
Management Fee
earned in Indonesia
B5S ID keeps
Operational Funds
to operator
Operator 🇮🇩
Pays staff, PHR, income tax
✅ Clean. Owner's share is deducted offshore — no Indonesian person pays a foreign person. Management fee earned in Indonesia. Operator's bank shows real business income, real expenses, real tax payments. No PPh 26
02 If All Funds Go Through Indonesia First
🌏 International
🇮🇩 Indonesia
Guest
pays
Airbnb
all funds
Operator 🇮🇩
owner's share
Owner 🇦🇺
⚠️ PPh 26 triggered — 20% withholding tax
❌ The 20% tax isn't even the real problem. To pay PPh 26 properly, the operator must:
  • Register with DJP as a PPh 26 withholding agent
  • File monthly returns showing payments to a foreign person
  • Create a documented paper trail: who is this foreigner? Why are they receiving money? What's the arrangement?
  • That's the thread that, when pulled, invites questions about the entire ownership structure

Even doing it "correctly" draws exactly the kind of attention you don't want.
03 What Italy Did — And Indonesia Will Likely Follow
Guest
pays
Airbnb
21% withheld
sent directly
Italian Tax Office 🇮🇹
79% remaining
paid out
Host
Italy forced Airbnb to become the tax agent. The platform now withholds income tax at source and sends it directly to the government — before the host sees a cent. Italy went through the exact same stages Indonesia is going through now: licensing first, platform verification second, tax withholding at source third. Indonesia is currently at stages one and two. Stage three is coming.
04 When Indonesia Follows Italy — Proposed Structure Still Works
🌏 International
🇮🇩 Indonesia
Guest
pays
Airbnb
PHR withheld
sent directly
Indonesian Tax 🇮🇩
Post-tax revenue
pays out
Bali 5 Star
Australia 🇦🇺
Owner's Share
stays offshore
Owner 🇦🇺
Operational funds
+ management fee
sent to Indonesia
Bali 5 Star
Indonesia 🇮🇩
Management Fee
Operational Funds
Operator 🇮🇩
✅ The structure doesn't just survive — it gets cleaner. Tax is handled at the platform level before anyone sees the money. Owner's share is still deducted offshore. Management fee still earned in Indonesia. Operator still receives real business income. No PPh 26. Future-proof.
05 All Funds Through Indonesia + Italy Model = Worst Case
🌏 International
🇮🇩 Indonesia
Guest
pays
Airbnb
PHR withheld 10%
BAPENDA 🇮🇩
90% remaining
all to Indonesia
Operator 🇮🇩
Owner's share
PPh 26: 20%
Owner 🇦🇺
Mgmt fee to B5S ID
then how does she
get money out?
B5S ID Shareholder?
PPh 26 again: 20%
💀 What happens to the owner's share — example on IDR 35M/month
Owner's share (gross) IDR 35,000,000
PPh 26 withheld in Indonesia (20%) - IDR 7,000,000
Owner receives IDR 28,000,000
Owner's home country tax on full IDR 35M (e.g. 32.5%) - IDR 11,375,000
↳ Can they offset the Indonesian PPh 26 already paid? Only with paperwork
↳ Will the operator issue a correct bukti potong PPh 26? Almost certainly not
Without paperwork: total tax on owner's share up to 52.5%
🔒 The management company extraction problem
Bali 5 Star ID earns management fee in Indonesia ✓ Taxed locally
But the shareholder/owner of B5S ID is a foreign person...
Dividend to foreign shareholder? PPh 26: 20%
Fee paid to Australian parent company? PPh 26: 20%
Home country tax on that income? + another 30-45%
Same problem, same wall. Money goes in, can't come out cleanly. 💀

This is a dead end. There are only three options:

1️⃣ Pay the PPh 26 properly — owner loses up to 52.5% of their share if paperwork isn't perfect. No foreign owner will accept this. The management company owner faces the same wall getting her own money out. The economics of the business collapse.
2️⃣ Don't pay PPh 26 — which means you're not actually legal. This is what most people do today. But with the new licensing, OSS registration, and PHR reporting, DJP has full visibility. The operator's bank shows money going offshore to foreign people every month. It's only a matter of time before it's flagged. This is the opposite of being fully compliant.
3️⃣ Deduct the owner's share offshore before funds enter Indonesia — no Indonesian person pays a foreign person, no PPh 26 is triggered, no documentation nightmare, no double taxation. The operator still runs a real, visible, compliant business in Indonesia. This is Scenario 01.
❌ There is no version where all funds flow through Indonesia AND foreign owners get paid AND everyone is fully compliant without the 20% hit. The people who say they do it this way are almost certainly not paying PPh 26 — which means they're not legal either. The only clean path is to put the deduction in the right place: offshore, before the money enters Indonesia.

The Bottom Line

The only thing that stays offshore is the owner's share — and that's the one thing that must stay offshore to avoid PPh 26. Everything else enters Indonesia. The management fee is earned in Indonesia. The operator runs a real, visible, compliant Indonesian business.

Bali 5 Star Australia → Bali 5 Star Indonesia
Same company group. Simple transfer. Smarter accounting.