How to Build a PT PMA Investment Plan Without Double-Counting Paid-Up Capital

To avoid double-counting, treat paid-up capital as a funding source, not as an additional investment-use line. The PT PMA investment plan should describe qualifying fixed assets, construction or other permitted project items, and working capital for each activity and location under BKPM Regulation No. 5 of 2025. Funding may come from paid-up equity, shareholder loans, external finance, or operating cash. Adding the IDR 2.5 billion equity figure on top of the assets and working capital funded by that same money counts one economic resource twice.

Use a sources-and-uses workbook. On the left, list equity and other financing. On the right, list project deployment. Add timing, KBLI, location, vendor or cost driver, OSS category, accounting code, and LKPM evidence. Before filing, reconcile the workbook through a PT PMA investment planning review and apply any activity-specific calculation rule or sector override.

Key takeaways

• Paid-up capital is funding; assets and working capital are uses of funding.
• The sources total and uses total should reconcile over the project schedule without being identical at every date.
• Do not list the same cash as paid-up capital, working capital, and bank balance in the investment total.
• Build each use from quantities, prices, timing, and operating assumptions.
• Use the same project codes in OSS planning, accounting, and LKPM reporting.

In this article

• Start with sources and uses
• Build fixed investment
• Calculate working capital
• Apply project rules
• Tie funding to schedule
• Convert plan into evidence

Start with two sides of the project

Sources answer where money comes from: paid-up equity, additional equity, shareholder loans, bank finance, customer deposits where lawful, and internally generated cash. Uses answer where the project deploys resources: equipment, fit-out, construction, technology, inventory, pre-operating items where permitted, and working capital. The same rupiah can appear once as a source and once as a use because those are opposite sides of the plan; it should not appear twice within uses.

Add opening and closing cash so timing works. If shareholders pay equity before the asset is purchased, the interim bank balance is not an extra investment use. It is unspent funding. When the company purchases the asset, cash falls and the asset rises. This simple balance-sheet logic prevents a plan from treating the deposit, bank balance, and asset as three separate investment items.

Build fixed investment from quantities and deployment

List each asset category with quantity, unit cost, supplier basis, currency, tax or import treatment, delivery date, commissioning date, project owner, location, useful life, and licence dependency. Grouping may be appropriate for minor items, but material equipment should remain traceable. If land or buildings are involved, apply the treatment prescribed for the activity rather than assuming universal inclusion or exclusion.

Separate assets already owned by a foreign parent from assets the PT PMA will purchase, lease, licence, or receive as a contribution. Each route has different legal, customs, tax, transfer-pricing, accounting, and ownership consequences. The investment plan should record the economic resource the Indonesian project will actually control and the evidence expected at realisation.

Calculate working capital from the operating cycle

Forecast inventory days, customer collection days, vendor payment days, payroll, rent, utilities, logistics, professional services, technology, marketing, insurance, and other operating costs for the defined planning period. Working capital is not simply the amount left after subtracting fixed assets from a threshold. It should explain how the business reaches its first stable operating cycle.

Avoid double-counting costs already capitalised into an asset or included in a construction contract. Avoid counting a refundable deposit both as an asset and an operating expense. Mark taxes that are recoverable or withheld separately where relevant. Use scenario assumptions for delayed customer collections or licence activation so the cash plan remains useful even if the formal investment classification differs.

Apply the correct KBLI, location, and exception method

The general foreign-investment framework applies total investment by business line and project location, but BKPM Regulation No. 5 of 2025 includes detailed methods and exceptions for certain activities. Build one schedule per required unit of analysis. Do not split or combine projects solely to achieve a preferred number, and do not reuse the same shared asset without an allocation.

Record the legal basis for special treatment and confirm current OSS implementation. If a sector regulator requires a higher paid-up capital, solvency, asset, deposit, or facility condition, include it in the funding and compliance plan without automatically treating it as the same OSS investment-use category. The capital-by-KBLI guide can support the question list.

Tie equity and financing to the deployment schedule

Create monthly or milestone columns showing opening cash, equity receipts, loans, operating receipts, asset payments, construction, working capital, taxes, and closing cash. The funding schedule should preserve the 12-month capital-proceeds controls and identify which payments are from equity or other sources. It should also show when additional funding approval is needed before the company becomes insolvent or misses a project milestone.

Do not assume the entire OSS investment plan must be funded as equity at incorporation. Equally, do not assume the IDR 2.5 billion baseline is enough cash for a capital-intensive project. The board should approve a realistic financing plan and understand dilution, debt service, FX, related-party, tax, bank, and covenant implications.

Convert the plan into accounting and LKPM evidence

Assign accounting and project codes before purchasing assets or incurring major costs. Each use line should point to the eventual evidence: purchase order, contract, invoice, customs document, payment, delivery, asset register, payroll, lease, or other record. During each reporting period, compare planned timing and amount to actual realisation and explain variance.

A clean reporting bridge has four columns: original plan, approved revision, period actual, and cumulative actual. It should show why a vendor, price, asset, location, or launch date changed. Do not rewrite the original plan to make every variance disappear. Management decisions and supporting evidence are part of the investment story.

Final decision

The double-counting fix is conceptually simple: equity and loans are sources; assets and working capital are uses. Add timing and evidence so the workbook also functions as a cash forecast and reporting bridge.

Once the plan is tied to KBLIs, locations, project codes, approvals, and actual transactions, it can support OSS, shareholders, banks, accountants, and LKPM without inventing a second use for the same paid-up capital.

Related insights

• Minimum Investment vs Paid-Up Capital in Indonesia
• PT PMA Capital Requirements by KBLI
• PT PMA Capital Proof for Bank Account Opening