Business actors registered inside KEK Sanur can import capital equipment for their licensed activity — imaging systems, surgical suites, laboratory analysers, sterilisation lines — without paying Indonesian import duty, and with import VAT and Article 22 income tax not collected at the border. The legal basis is Government Regulation 40/2021 on Special Economic Zones, implemented through PMK 237/PMK.010/2020 (amended by PMK 33/PMK.010/2021). The facility applies as long as the goods stay in the zone and serve the licensed activity.
In cash terms, the exemption typically removes 10 to 20 percent from the landed cost of imported medical equipment versus importing outside the zone. The exact figure depends on tariff line: duty on medical devices runs 0-5 percent, import VAT is 11-12 percent, and Article 22 prepaid tax adds 2.5 percent or more of customs value. Since imported equipment is often 40-60 percent of capex for a medical fit-out, that gap can change which projects clear an investment committee.
Where the Exemption Comes From
Indonesia’s SEZ regime rests on Law 39/2009 on Special Economic Zones (amended by the Job Creation Law), Government Regulation 40/2021, and PMK 237/PMK.010/2020. KEK Sanur, created by Government Regulation 41/2022 as Indonesia’s first SEZ for health and medical tourism, covers roughly 41 hectares in Sanur, Denpasar, anchored by Bali International Hospital under the InJourney state enterprise group. Its master plan reserves space for private clinics, specialist centres, diagnostics, and wellness facilities: the tenants for whom equipment costs matter most.
What the Fiscal Package Covers
For a business actor inside the zone, import-side facilities generally include duty exemption or suspension on capital goods used for the licensed activity while they remain in the zone; import VAT not collected on qualifying goods; and Article 22 import tax not collected, avoiding a prepaid cost at clearance. Excise exemption applies where relevant. Separately, larger SEZ investments can also qualify for a multi-year corporate tax holiday that stacks with this import facility.
Medical services in Indonesia are VAT-exempt, so a clinic outside the zone cannot credit input VAT on imported equipment: that 11-12 percent is a true, unrecoverable cost. Inside the SEZ it is simply not collected, so the saving is real margin, not deferral. Article 22 tax is normally creditable against year-end corporate tax, so its exemption is mainly a cash-flow benefit during build-out.
What Qualifies as Capital Goods
The facility covers goods used to develop and operate the licensed activity: diagnostic imaging, surgical and procedural equipment, laboratory analysers, sterilisation and CSSD lines, dental and CAD/CAM units, and rehabilitation or wellness equipment tied to the licensed scope. Consumables, general fit-out, and vehicles are assessed restrictively, and anything not plausibly connected to the licensed activity is struck from the application. Every item must sit on an approved masterlist before it ships.
How the Process Works
In practice: form the right entity, typically a PT PMA with matching KBLI classifications (see our PT PMA setup for KEK Sanur guide); secure business-actor status through OSS and the KEK Sanur Administrator; complete customs registration, including the IT inventory system tracking goods in and out of the zone; and import under SEZ customs procedures only after the equipment list is approved as a masterlist. Approvals should run parallel with design and procurement: the projects that save the most draft schedules with the masterlist in mind from day one.
What It Does to the Capex Model
Take an illustrative clinic importing USD 4 million (CIF) of equipment. Figures below are indicative ranges for modelling, not quotations; actual rates depend on each item’s tariff classification.
| Cost line | Outside the SEZ | Inside KEK Sanur |
|---|---|---|
| Import duty (0-5%) | ~USD 0-200,000 | Exempt / suspended |
| Import VAT (11-12%, unrecoverable) | ~USD 440,000-480,000 | Not collected |
| Article 22 tax (2.5%+, creditable) | ~USD 100,000+ at border | Not collected |
On those assumptions, the permanent saving sits roughly between USD 440,000 and 680,000, plus over USD 100,000 of cash freed at clearance. Because the facility removes border taxes rather than refunding them later, the project needs less peak funding during fit-out, when medical projects are most fragile. Phased programmes (diagnostics core first, procedural suites later) can structure the masterlist to match, rather than importing everything in one tranche.
Conditions and Limits
Goods must stay in the zone and serve the licensed activity; releasing them into general customs territory triggers the duties and taxes that were exempted. A regulated relief pathway may apply after a qualifying period in the zone, but it is not automatic, and misuse (diverting goods brought in under the facility) risks repayment, penalties, and revocation. Compliance also carries real overhead: inventory tracking, reporting, and audits are ongoing costs. Verify any model against current PMK text before board approval.
Getting the Structure Right Before the Equipment Ships
Entity setup, zone registration, and masterlist approval must all be in place before the first crate leaves the supplier. We work as an independent advisory desk: we do not operate clinics or own facilities in the zone, and we help arrange the entry pathway through established contacts in Bali: licensing coordination and introductions to the zone administrator, legal counsel, and customs specialists. Our medical tourism business entry advisory is the right starting point. Reach us on WhatsApp at +62 811-3941-4563 or by email at bd@juaraholding.com with your equipment budget and service scope.
This guide is general information, not financial or legal advice. Verify current regulations with licensed advisors.