Abstract: The digital economy presents various new business models that open up many opportunities for tax avoidance schemes, so the OECD recommends an action plan on digital economics in the form of an Action Plan 1. Previously this recommendation has not been a priority yet for the Indonesian Tax Authority. On the other hand, DGT has not met the tax revenue target in the last five years, while it has been known that the transaction value of the digital economy is very large and has not been taxed.