<![CDATA[This study analyzes the application of the ultra vires doctrine in the context of executive authority in the field of taxation, with a focus on Constitutional Court Decision Number 25/PUU-XXIII/2025, which examines the constitutional limits of the Minister of Finance's authority. Using a normative-dogmatic legal method, this study examines the relationship between the principles of separation of powers and the rule of law in assessing the administrative actions of the Minister of Finance that are suspected of exceeding his authority (over capacity of power). The results of the study show that the Minister of Finance's action in issuing PMK No. 184/PMK.01/2017 is still within the intra vires corridor because it is based on explicit delegation of law and is technical-administrative in nature without creating new substantive norms. The Constitutional Court emphasized that the delegation is constitutional as long as it does not interfere with judicial functions and maintains proportionality between fiscal administration effectiveness and legal accountability. Doctrinally, the application of the ultra vires doctrine in this case strengthens the checks and balances mechanism and affirms the rational boundary between executive freedom of action and constitutional supremacy. In practical terms, this study implies the need for tax law reform that clarifies the standards for delegation of authority and strengthens the role of judicial oversight in ensuring the independence of the tax courts and national fiscal accountability.]]>
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