<![CDATA[The implementation of hostage sanctions (gijzeling) in Indonesian tax law remains contentious, as it allows taxpayers' liberty to be restricted without prior judicial determination, raising concerns over fundamental rights and equality before the law. This study aims to evaluate legal protection for taxpayers subject to gijzeling and proposes reforms to align effective tax enforcement with constitutional rights. This study employs normative legal research using statutory, philosophical, interpretative, and case approaches. Legal materials were gathered through library-based research and analyzed systematically using an inductive method. The findings indicate that the current legal framework offers fragmented rather than comprehensive protection of taxpayers' rights. The General Taxation Law (UU KUP) does not explicitly recognize taxpayers' fundamental rights, while the Tax Collection Law (UU PPSP) grants broad coercive powers to tax authorities without sufficient procedural safeguards. Judicial practice further demonstrates that courts primarily emphasize formal compliance with tax collection procedures, resulting in limited protection of taxpayers' rights to legal certainty, information, privacy, and due process. To address these shortcomings, this study proposes reformulating the UU KUP by explicitly incorporating taxpayers' fundamental rights and revising the UU PPSP by clarifying the legal standard of good faith, establishing certainty regarding judicial review, and strengthening compensation and rehabilitation mechanisms. This study contributes to the literature by examining gijzeling from the perspective of equality before the law and taxpayer legal protection, thereby offering a normative framework for balancing state fiscal interests with constitutional rights in tax enforcement.]]>
