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Indonesian Journal of Law and Society (2020) 1:2 199-218 
ISSN 2722-4074 | https://doi.org/10.19184/ijls.v1i2.23433 
Published by the University of Jember, Indonesia 
Available online 20 October 2020 
 
 

_____________________________ 
 
* Corresponding authors’ e-mail: misbahulilham313@gmail.com 

Compensation Arrangements in Expropriating 
Goods and Equipment: An Indonesian Experience 
 
Misbahul Ilham* 
University of Jember, Indonesia  
 
Bhim Prakoso 
University of Jember, Indonesia  
 
Ermanto Fahamsyah 
University of Jember, Indonesia  
 

ABSTRACT. After the change of oil and gas production sharing contract scheme in 2017, the 
expropriation of goods and equipment has become the main clause in the Production Sharing 
Contract (PSC) contract. As a substantial production subsidiary, oil and gas exploitation is 
controlled by PSC. This paper aimed to examine the PSC contract, Oil and Gas Law, and 
upstream oil and gas business ordinance to expropriate goods and equipment. The PSC outline 
contains ownership of natural resources, the working area of oil and gas operations, oil and gas 
reserves, capital, and sophisticated supporting goods and equipment. However, the problem in 
the contract dealt with the ownership of goods and equipment purchased by the contractor. The 
cooperation contract regulated that goods that support oil and gas operations were included in 
the category of State Property without compensation. The provisions in the contract tended to 
be detrimental to the contractors who have carried out the exploration stage but did not find oil 
and gas reserves until the specified time limit. This paper used normative legal research to 
analyze the regulation of clause the expropriation of goods and equipment and statute approach 
to explore the clause from various regulations. The result showed the acquisition of ownership 
of goods and equipment in the PSC, upstream oil and gas business regulation was not 
regulating the compensation arrangements. 

KEYWORDS: Natural Resources Law, Upstream Activities, Compensation Arrangements. 
 

 
 

 

Copyright © 2020 by Author(s) 

This work is licensed under a Creative Commons Attribution-ShareAlike 4.0 International 
License. All writings published in this journal are personal views of the authors and do not 

represent the views of this journal and the author's affiliated institutions 

  

Submitted: 10/09/2020   Reviewed: 12/09/2020   Revised: 15/10/2020   Accepted: 16/10/2020 



200 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

I. INTRODUCTION 

Natural resource management of oil and gas generates enormous returns 
from their production, critical to a global resource-led political economy 
development. For countries with enormous natural resources such as 
Indonesia, Venezuela, and Saudi Arabia, they experience economic and 
controlling stagnation or difficulties.1 Thus, Indonesia’s dependence on oil 
and natural gas is relatively high due to a large amount of natural wealth.2 
The oil and gas industry has experienced significant volatility in the last five 
years, both in Indonesia and globally,3 caused by global geopolitical and 
economic considerations playing a significant role in driving the oil and gas 
industry. Currently, Indonesian people are also requisite for oil and gas 
products considered from increased petroleum consumption, domestic 
energy, and industrial raw materials.4 By taking into account the enormous 
need for oil and gas products, Indonesia sets control of oil and gas by the 
state. However, the right to control owned by the state must also consider 
the products that must aim at the community's welfare.  

Managing the oil and gas industry is high risk due to the dwindling supply 
of nature and the high cost of procuring and refining resources. The state 
in the production of oil and natural gas has the function to regulate and 
manage natural wealth such as land, water, and other natural resources. 
The constitutional content in the economic sector must be structured as a 
joint effort based on the principles.5 In addition, the production branches, 
which are essential and have a bearing on the livelihood of the people, are 

 
1  Genio Ladyan Finasisca , Tri Hayati, “Domestic Beneficiation Policy In Mining Sector : 

A Case Study Of Indonesia” (2020) 7:07 J Crit Rev, online: <http://www.jcreview. 
com/fulltext/197-1588918536.pdf?1589182258>. 

2  Alan Gelb, Benn Eifert & Borje Nils Tallroth, The Political Economy of Fiscal Policy 
and Economic Management in Oil-Exporting Countries, Policy Research Working 
Papers (The World Bank, 2002). 

3  Fourina Permatadewi, “Oil and Gas in Indonesia - Investment and Taxation Guide 
2018” at 152. 

4  Ana Fitriyatus Sa’adah, Akhmad Fauzi & Bambang Juanda, “Peramalan Penyediaan 
dan Konsumsi Bahan Bakar Minyak Indonesia dengan Model Sistem Dinamik” (2017) 
17:2 J Ekon Dan Pembang Indones at 118–137. 

5  Ibnu Sina Chandranegara, “Desain Konstitusional Hukum Migas untuk Sebesar-
Besarnya Kemakmuran Rakyat” (2017) 14:1 Jurnal Konstitusi at 45. 



201 | Indonesian Journal of Law and Society 

 

directly controlled by the state on the condition that they are used 
maximally for the prosperity of the people. Under the current contract, the 
government appointed the company as a contractor in a licensed area.6 In 
the current condition, Oil and gas investment return sharing scheme in the 
cooperation contract is divided into two. They are PSC cost recovery (PSC 
CR) and PSC gross split (PSC GS).7 The cost recovery scheme is that the 
state will reimburse all costs related to oil and gas revenues, then the oil and 
gas proceeds will be given to the state with a larger portion with a 
distribution range of 85% for the state and 15% for contractors.8 
Meanwhile, the gross split scheme states that the contractor bears all costs 
related to the acquisition of oil and gas, then the contractor will get a more 
significant share of the revenue from oil and gas, the scheme can be 57% 
for the state and 43% for the contractor.9 

Several implementing regulations state that all goods and equipment 
purchased by contractors in implementing petroleum operations become 
state property and are managed by the Special Task Force for Upstream Oil 
and Gas Business Activities.10 The regulations in question are Government 
Regulation 35/2004, Government Regulation 27/2017, Government 
Regulation 53/2017, Minister of Finance Regulation 89/PMK.06/2019, 
Minister of Finance Regulation 02/PMK.05/2011 and Minister of Energy 
and Mineral Resources Regulation 8/2017. The government's treatment of 
goods and equipment that should belong to the contractor and directly 

 
6  Dwi Atty Mardiana, Fadhlia, Ridha Husla, RS Trijana Kartoatmodjo, “Assessing 

Indonesia’s Upstream Petroleum Fiscal Regimes Choices” (2019) 8:11 Int J Sci Technol 
Res, at 2449. 

7  Buletin Skk Migas, “Membuka Harapan Baru dari Skema Gross Split” (2017) 24. 
8  Hari Sutra Disemadi & Sahuri Lasmadi, “Utilizing Production Sharing Contracts 

(PSCs) as a Means for the Protection of Indonesia’s Natural Resources” (2019) 6:3 
Lentera Hukum at 393. 

9  Hari Sutra Disemadi & Sahuri Lasmadi, “Utilizing Production Sharing Contracts 
(PSCs) as a Means for the Protection of Indonesia’s Natural Resources” (2019) 6:3 
Lentera Hukum at 393. 

10  Duwi S Ariyani, “Penataan Barang Milik Negara Beleid Aset Hulu Migas Bikin Rumit 
Birokrasi”, Koran Bisniscom (Oktober 2017), online: <https://koran.bisnis.com/read/ 
20171013/451/698733/penataan-barang-milik-negara-beleid-aset-hulu-migas-
bikin-rumit-birokrasi>. 



202 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

states that the goods that have been used in oil and gas operations in their 
working area belong to them.   

This research examined the government's arrangement of the expropriation 
of contractor goods and equipment. The compensation arrangement in oil 
and gas law must follow Government Regulation 35/2004 on upstream oil 
and gas business activities and the cooperation contract. The first section of 
this paper will discuss the legal and regulatory framework of the upstream 
oil business contracts in Indonesian experience from It Is beginning until 
the shift of the current scheme. The second and third discussions will 
elaborate on the expropriation of ownership of goods and equipment and 
the compensation after the current alteration scheme. 

 

II. METHODS 

This research uses normative legal analysis to examine the legal framework 
of upstream oil and business activities to explore problems by looking at 
norms and their application, and a conceptual method to analyze doctrine 
and legal views as material for solving problems. The legal sources used 
consist of primary legal materials, secondary legal materials, and non-legal 
materials. 

 

III. LEGAL AND REGULATORY FRAMEWORK OF THE 
UPSTREAM OIL BUSINESS CONTRACTS 

A. Legal Aspect of Upstream Oil Contracts 

Oil and gas business activities are conditional on investment activities with 
significant capital, thus to facilitate the legal relationship between the 
owners of capital and the recipients of capital, a contract called a 
Cooperation Contract is formed.11 Under Article 1:14 of the Oil and Gas 
Law, the contract is interpreted as a Production Sharing Contract or other 
cooperation contracts in exploitation and exploration activities that are 
more profitable for the state. The results are used for people’s prosperity. It 

 
11  Sulaiman, “Rekonstruksi Hukum Minyak dan Gas Bumi yang Berkeadilan di Indonesia” 

(2016) 18:2 Kanun Journal Ilmu Hukum at 221. 



203 | Indonesian Journal of Law and Society 

 

indicates other types of contracts other than production sharing contracts 
whose existence is still recognized. Although Indonesia has made changes 
two times, the cooperation system changes in the upstream oil and gas 
business activities. Cooperation Contracts are still expected to be a tool for 
the government to improve relations with investors in managing the 
upstream oil and gas business. Another objective is to assure accountable 
processing, transport, storage, and commercial businesses through fair and 
transparent business competition. It includes guaranteeing the efficient and 
effective supply of oil and gas as a source of energy and meeting domestic 
needs, promoting national capacity, increasing state income, and enhancing 
public welfare and prosperity equitably while maintaining the conservation 
of the environment. 

 

B. Concession System For Upstream Oil Contracts 

This system has been in effect during the era of the Dutch East Indies 
government. In this system, mining companies that can manage oil and gas 
mining are given mining rights and control over land. The contractor has 
full control over the oil being mined, and the contractor is obliged to pay 
royalties to the state. Howard R Williams and Charles J Meyer12 in the 
Manual of Oil and Gas Terms provide an understanding that the 
concession system is: 

"An agreement (usually from host government permitting a foreign 
petroleum company to prospect for and produce oil in the area subject 
to the agreement.) The terms ordinarily include a time limitation and 
provision for royalty to be paid to the government.” 

The concession referred to above is defined as an agreement between the 
state that owns or holds the oil and gas mining authority and the investor, 
whereby the investor will get the right to explore and, if successful, produce 
and market oil and natural gas without involving the concession-giving 
country and its management. 

 
12  Howard R Williams, Patrick H Martin, Charles J Meyers, Manual of Oil and Gas 

Terms: Annotated Manual of Legal, Engineering and Tax Words and Phrases, 17th 
Edition ed (LexisNexis). 



204 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

According to A Madjedi Hasan 13 several provisions in the concession 
system can be described as the patterns and conditions contained in the 
concession system, namely: exclusive rights to the concession holder for a 
certain time (75 years) to carry out exploration and exploitation of 
petroleum; and the right to sell it including by-products (refined) produced 
from the concession area. In this concession system, the land given varies 
but is generally very broad and the rights granted to concessionaires are 
almost unlimited and full of excessive privileges. The payment for the 
concession shall only be in the form of royalty payments (based on 
production volume at a fixed rate). Concession holders are not subject to 
income tax. Ownership of oil and gas resources based on the concession 
system is right in rem, which can be used as collateral. Rightsholders will 
become owners as soon as these resources are produced. The government is 
not involved in the ownership of the management of operational activities 
other than receiving royalty payments and other levies. 

The relationship between the host country and the company at the start 
of the concession system allowed the company to impose asymmetrical 
conditions on the host.14 With this concession system, the state as the 
owner of natural resources gives the right to seek, develop, and export to 
a company (generally a foreign company) freely from a vast area for an 
extended period in exchange for a certain amount of payment and other 
benefits. Thus, the government only has the right to receive commercial 
uses, which initially take the form of royalties and turn into royalties and 
taxes. 

 

C. Contract of Work for Upstream Oil Contracts 

The implementation of the contract of work has been in effect from 1960 
to 1963. This system was built for oil and gas mining companies only to be 
given the power to the government so that the contractor pays a tax of 56% 

 
13  A Madjedi Hasan, “Kontrak Pertambangan Minyak dan Gas Bumi, (Training on 

The Law of Energy and Mineral Resources)” in (Faculty of Law, Universitas 
Indonesia, 2010) at 20. 

14  Ibid. 



205 | Indonesian Journal of Law and Society 

 

directly to the government. Besides that, the Generally Accepted 
Accounting Procedure (GAP) needs to be applied for which the restriction 
on operating costs (Cast Recovery Calling) is 40% and has been removed. 
The definitive work contract is outlined in Article 1 of the Decree of the 
Minister of Mining and Energy 1409.K/201/M.PE/1996 on the 
procedures for processing applications for the granting of mining rights, 
principle permits, work contracts, and work agreements for coal mining 
companies (PKP2B). that is; an agreement between the Indonesian 
government and a foreign private company or a joint venture between 
foreign and national for exploitation of natural resources in the form of 
minerals.15 

The definition above constructs a work contract as an agreement. The 
subjects in the agreement are the government and foreign companies in a 
joint venture between foreign and national companies. Ismail Sunny16 
stated that in the implementation of a work contract, it refers to as foreign 
capital cooperation in the form of a work contract which occurs when a 
foreign investment forms an Indonesian legal entity and this legal entity 
enters into cooperation with a legal entity that uses national capital. 
Meanwhile, Sri Woelan Azizi has a different meaning that the contract of 
work is in the presence of a collaboration in which a foreign party forms an 
Indonesian legal entity. This Indonesian legal entity cooperates with an 
Indonesian legal entity that uses Indonesian capital.17 

Salim defines a work contract as an agreement made between the 
Indonesian government and foreign contractors solely and/or is a joint 
venture between a foreign legal entity and a domestic legal entity to carry 
out exploration and exploitation activities in the field.18 General mining, 
according to the time frame agreed by both parties. The work contract 

 
15  Jennifer McKay & Balbir Bhasin, “Mining Law and Policy in Indonesia: Issues in 

Current Practice that Need Reform” (2001) 19:4 J Energy Nat Resour Law at 329–343. 
16  Ratnasari Fajariyah Abidin, “Aspek Yuridis Renegosiasi Kontrak Karya di Indonesia 

(Studi Kontrak Karya Antara Pemerintah Republik Indonesia Dengan PT.Freeport 
Indonesia)” (2018) 11:01 Al-Risal at 19. 

17  Ibid. 
18  Salim HS, Hukum Pertambangan Mineral dan Batubara (Jakarta: Sinar Grafika, 

2014). 



206 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

regulates the legal relationship between the parties and governs the object 
of the work contract. In general, the elements of a work contract are a 
contractual (agreement made by the parties), legal subject, the existence of 
objects, general mining, and term in the contract. 

 

D. Cooperative Contract for Upstream Oil Contract 

Cooperation contracts that foreign private companies with the government 
have executed have a broad impact on society.19 The positive consequences 
of the cooperation contract are job opportunities and technology transfer. 
Article 1 of the Oil and Gas Law confirms the definition of a cooperation 
contract, namely: 

"Cooperation Contracts are production sharing contracts or other forms 
of cooperation contracts in exploration and exploitation activities that are 
more beneficial to the state and the results are used for the greatest 
prosperity of the people." 

Production Sharing Contracts translate the Cooperation Contracts in the 
Oil and Gas Law and several other laws and regulations. Permanent 
establishment. Production Sharing Contracts have been implemented in 
Indonesia since 1964. Production Sharing Contracts (PSCs) were born at 
that time to overcome the problems of limited domestic capital, 
technology, and human resources faced in oil and gas operations.20 

 

IV. THE EXPROPRIATION FOR UPSTREAM OIL AND GAS 
BUSINESS CONTRACTORS 

The regulation of goods and equipment is regulated in Cooperation 
Contracts and various laws and regulations relating to upstream oil and gas 
business activities. The business Entity in the Cooperation Contract is 
referred to as the Cooperation Contract Contractor as one of the parties 
interested in goods and equipment to support oil and gas exploration and 
exploitation activities. In its operation, the Cooperation Contract 

 
19  Law 22/2001 on Oil and Natural Gas. 
20  Rudi M Simamora, Hukum Minyak dan Gas Bumi (Jakarta: Djambaran, 2000) at 

271. 



207 | Indonesian Journal of Law and Society 

 

Contractor requires supporting goods and equipment in one way, namely 
buying the supporting goods and equipment. The initial stage in the 
contract agreement between the state and the Cooperation Contract 
Contractor has general rights in oil and gas activities. The state has a 
working area, oil and gas reserves, and ex-terminated BMN. Cooperation 
Contract Contractors as investors must have financial, human resources 
(HR), and technology. The number of capital assets (CA), investment 
assets (IA), limited inventories, seismic material and wells, ground wells, 
and office equipment at the exploration stage.21 

Significant additions to CA, IA, and supplies in production facilities and 
equipment, wells, supply materials, offices, and housing. Until the final 
stage, namely the termination of the contract by significantly reducing CA, 
IA, and inventories by returning to the state.22 The clauses in the PSC 
Contract (Production Sharing Contract) and Article 78 of Government 
Regulation 35/2004 concerning upstream oil and gas business activities.  

"All goods and equipment that are directly used in the upstream oil 
and gas business activities purchased by the contractor become state 
property/assets whose development is carried out by the government 
and managed by the executing agency." 

In addition, it is regulated in Article 3 of PMK 89/PMK.06/2019 on the 
management of state property originating from the implementation of 
cooperation contracts for upstream oil and gas business activities, which 
states: 

"Goods purchased or obtained through the import process for use or 
intended for use by contractors in the implementation of upstream oil 
and gas business activities are state property owned by oil and gas after 
landing at seaports, airports or other places. The purchased goods 
have fulfilled the customs obligations of the imported destination 
under the statutory regulations. There is a difference regarding the 
goods that will become BMN of imported oil and gas and those that 
are not imported. This status is deemed essential to ensure that the 

 
21  Dr Grace Li, “The PRC Contract Law and Its Unique Notion of Subrogation” (2009) 

4:1 at 10. 
22  Ibid at 12. 



208 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

goods that will become BMN oil and gas originate from abroad or 
domestically." 

In general, goods are part of state assets which are specific units that can be 
valued, counted, measured, and weighed. Meanwhile, state-owned goods 
are defined in Article 1:1 of Government Regulation 27/2014 on 
Management of State/Regional Property. All goods purchased or obtained 
at the expense of the State Budget or originating from other legitimate 
acquisitions, excluding money and securities. Thus, the State, Provinces, 
Regencies/Municipalities as state institutions have property rights and 
other rights proportionally and under the principles of limitation and 
conditions stipulated in statutory regulations. Likewise, individual legal 
subjects and civil legal entities. Public legal entities can sell, rent, utilize 
and or manage the goods they own.23 

The definition of State Property (abbreviated as SP) is also stated in Article 
1:3 of Minister of Finance Regulation No. 171/PMK.05/2007 on Central 
Government Financial Accounting and Reporting System which outlines: 

"BMN is all goods purchased or obtained at the expense of the State 
Budget or derived from legitimate acquisitions. The classification of 
goods referred to above is tangible goods that can be assessed, 
counted, measured, and weighed, excluding money and securities." 

Goods and equipment in oil and gas operations are categorized as state-
owned goods obtained from other legal acquisitions according to Article 
2:2 of the Government Regulation 27/2014 on the Management of State 
Property. Among others, goods obtained from a gift/donation or the like, 
goods obtained as an implementation of an agreement/contract, goods 
received under the provisions of law, or goods received based on a court 
decision that has acquired permanent legal force. BMN managers who have 
the authority to regulate and manage SP. It is the Minister of Finance as 
general treasurer of the state that becomes the manager of state property 
authorized and responsible for the regulation and implementation of 
policies relating to BMN management.  

 
23  McKay & Bhasin, "Mining Law and Policy in Indonesia," supra note 15. 



209 | Indonesian Journal of Law and Society 

 

The legal position in regulating the ownership of goods and equipment for 
upstream oil and gas business activities is used as the basis for determining 
the position where a legal subject or legal object is placed. It has the 
function and purpose of carrying out an activity allowed and not allowed in 
the cooperation contract. Special Work Unit For Upstream Oil and Gas 
Business Activities (SKK Migas) is authorized by the state as a substitute 
for the Implementing Body.24 The executing agency is an agency 
established to exercise control in the upstream oil and gas business 
activities. As the holder of the power, the state delegates based on Article 4 
of the Oil and Gas Law, which regulates that the government with mining 
rights forms an executing agency.25 The authority of the executing agency 
in this activity is to supervise the upstream oil and gas business activities in 
and throughout the areas described and described in the contract. The 
cooperation contract contractor in the said contract must have the financial 
capacity, technical skills, and expertise needed to carry out petroleum 
business under the clauses in the cooperation contract.26 

Control over oil and gas refers to the constitutional basis which delegates 
the authority to control (in the sense of exploiting and managing) 
important production branches (oil and gas) and controlling the livelihood 
needs of many people to the state and can be delegated to business entities 
in the form of permanent businesses. The state's position as the holder of 
power rights is due to the sovereignty of its natural resources. Its control 
must be a priority to be of great value to the people's livelihoods.27 Oil and 
gas is a significant production, meaning that the oil and gas content in the 
land is very close to the products that people need from oil and gas 
production. As an essential and strategic production branch, the oil and gas 
sector has a different meaning from other countries, namely Malaysia. 

 
24  Affina Niken Al-Islami, “Legalitas Kontrak Kerjasama Minyak Dan Gas Bumi Pada 

Organisasi dan Tata Kerja Satuan Kerja Khusus Pelaksana Kegiatan Usaha Hulu 
Minyak Dan Gas Bumi”,p 21. 

25  M Ilham F Putuhena, “Politik Hukum Pengelolaan Hulu Migas Pasca Putusan 
Mahkamah Konstitusi” (2015) 4:2 at 17. 

26  Brigita P Manohara, Ahmad Redi, “New Oil And Gas Regulations In Indonesia To 
Prevent Corruption In Upstream Sector” (2020) 7:08 J Critical Review at 759. 

27  Putuhena, supra note 25. 



210 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

Malaysia in the Petroleum Act 28defines that ownership of oil and gas as an 
essential branch is not allowed to be transferred or controlled by the private 
sector. 

Act 144 Petroleum Development Act 1974. The entire ownership in, 
and the exclusive rights, powers, liberties, and privileges of exploring, 
exploiting, winning, and obtaining petroleum whether onshore or 
offshore of Malaysia shall be vested in a Corporation to be 
incorporated under the Companies Act 1965 or under the law relating 
to the incorporation of companies. 

Malaysian Law 144/1954 on Oil and Petroleum Development that all 
ownership in terms of exclusive rights, powers, freedoms, and privileges to 
explore, exploit, win and obtain petroleum either on land or off the coast of 
Malaysia will be given to A corporation to be incorporated under the 
Companies Act 1965 or under the laws relating to the incorporation of 
companies. The entire ownership of the exploration and exploitation of oil 
and gas in Malaysia, both on land and at sea, is transferred to a national 
corporation established under the Companies Act. Meanwhile, in 
Indonesia, the interpretation is different, when the Constitutional Court 
hearing on 29 April  2010 29stated that "what is important for the state is 
not only that it has a strategic role, but also controls the lives of many 
people and this management can be managed by the private sector." The 
state is given the task and authority to make policies (beleid), management 
(bestuutsdaad), regulation (regelended), management (beheersdaad), and 
supervision (toezichthoudendsdaad) over control of a production branch (oil 
and gas).30 Indonesia strictly regulates the state's position over control of oil 
and gas as an essential and strategic production branch controlled by the 
state. It has meaning in its practice, whether the state regulating oil and gas 

 
28  Petroleum Development Act, 144 1974. 
29  Putuhena, supra note 25. 
30  Lalang Tri Utomo, Achmad Busro, Ery Agus Priyono, “Aspek Hukum Penerapan Asas 

Kekuatan Mengikat Dalam Kontrak Bagi Hasil Minyak Dan Gas Bumi di Indonesia” 
5:4 Dipenogoro Law J at 3. 



211 | Indonesian Journal of Law and Society 

 

management plays a role in public law subjects (jury imperii) or civil law 
subjects (jury gestiones).31 

The parties' position becomes unbalanced with the state's position as the 
perfect subject. The state can change laws and prosecute legal subjects who 
break the law as an ideal legal subject. The concept of jury gestiones defines 
that the state as a subject of civil law is considered to have abandoned 
immunity to its sovereignty in connection with its actions in business 
activities.32The substance of the contract is inappropriate because it 
contradicts the concept of ownership which is intended for the most 
significant benefit of the people.33 Based on the explanation above, the 
state's legal position in this Cooperation Contract becomes the legal 
relationship between the first party as a sovereign state and the second 
party as a Cooperation Contract Contractor. Such profits must aim at the 
maximum possible welfare of the community.  

 

V. THE COMPENSATION ARRANGEMENTS OF UPSTREAM 
OIL AND GAS BUSINESS CONTRACTORS 

The disadvantages can be defined as a real loss that occurs because of 
default.34 The amount of the loss is determined by comparing the state of 
assets after default with the situation if there was no default. M. Yahya 
Harahap also interpreted more or less the same, namely compensation is 
defined as the real loss or "fletelijke nadeel" caused by the act of default.35 
Abdulkadir Muhammad emphasized that Articles 1243 to 1248 of the 

 
31  Huala Adolf, Dasar Dasar Hukum Kontrak Internasional (Bandung: Refika Aditama, 

2008) at 5. 
32  Sang Ayu Putu Rahayu, “Prinsip Hukum Dalam Kontrak Kerjasama Kegiatan Usaha 

Hulu Minyak Dan Gas Bumi” (2017) 32:2 Yuridika at 333. 
33  Maulana Arba’ Satryadin, Ery Agus Priyono & Budi Gutami, “Penerapan Asas 

Proporsionalitas Dalam Production Sharing Contract Pada Kegiatan Usaha 
Pertambangan Hulu Minyak Dan Gas Bumi” (2016) 5 at 18. 

34  R Setiawan, Pokok Pokok Hukum Perikatan (Bandung: BinaCipta, 1977) at 17. 
35  M Yahya Harahap, Segi Segi Hukum Perjanjian (Bandung: Alumni, 1982) at 66. 



212 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

Civil Code constitute a legal against debtors from arbitrary actions by the 
creditor due to default.36  

Nieuwenhuis broadly puts forward the term loss regarding the decrease in 
the assets of one party, which is caused by an act that violates the norm by 
the other party. Nieuwenhuis added that care must be taken to not cause 
harm as a difference between the situation before and after default or illegal 
acts.37 It is also essential to pay attention to the elements of compensation 
as stated in Article 1246 of the Civil Code: 

"Costs, losses, and interest that the debtor may be sued for 
compensation generally consist of the losses he has suffered and the 
gains that he should enjoy, without prejudice to the exceptions and 
changes that will be mentioned below." 

According to Abdul Kadir Muhammad, the following elements of 
compensation can be drawn  by the cost, losses due to damage, and 
expected interest or profit.38 Satrio considers more specifically that the 
elements of compensation are a substitute for the performance obligation of 
the engagement, part of the primary engagement obligations, such as 
improper performance.39 The compensation for losses suffered by creditors 
due to overdue performance is demanded to compensate for the principal 
performance obligations of the engagement and compensation for the 
delay. 

Regulations related to goods and equipment are not only regulated in the 
oil and gas cooperation contract, but several regulations also stipulate the 
same thing. Provisions regarding goods are regulated from Articles 78 to 81 
Chapter IX Utilization of Domestic Goods, Services, Technology and 
Engineering and Design Capabilities in Government Regulation 35/2004 
on Upstream Oil and Gas Business Activities. 

 
36  Abdul Kadir Muhammad, Hukum Perikatan (Bandung: Citra Aditya Bakti, 1990) at 

41. 
37  JH Nieuwenhuis, Pokok Pokok Hukum Perikatan (Airlangga University Press, 1985) at 

54. 
38  Abdul Kadir Muhammad, supra note 21 at 76. 
39  J Satrio, Hukum Perikatan (Perikatan Pada Umumnya) (Bandung: Alumni). 



213 | Indonesian Journal of Law and Society 

 

Managing goods and equipment includes physical and administrative 
activities ranging from storage, maintenance, release and delivery, 
recording, and reporting to meet needs and ensure the smooth operation of 
petroleum in the working area.40  

Contractors using a PSC GS scheme must maintain and maintain 
documents related to the acquisition, maintenance, replacement, 
modification, and ownership of these goods and equipment according to 
the provisions that are still in effect while they are still in the upstream oil 
and gas business activities.41 The objective of asset management in the form 
of goods and equipment from upstream oil and gas business activities is 
effective, efficient, and transparent based on the principles of accountability 
under the provisions and laws in force to provide maximum benefits to the 
state while still prioritizing the prosperity and welfare of the people.42 The 
form of management of goods and equipment originating from the assets 
of a cooperation contract contractor, namely through the existence of a 
special arrangement from the Minister of Finance Regulation 
135/PMK.06/2009 on Management of State Property Derived from 
Cooperation Contract Contractors. 

The general principle in the above regulation regulates that State Property 
(BMN) is state assets that will later be used and acquired or purchased by 
the Cooperation Contract Contractor to implement the contract between 
the Republic of Indonesia and the Cooperation Contract Contractor.43 
Goods and equipment categorized as Asset Contractors in a cooperation 
contract are regulated in Article 2(1) and (2) of Ministry of Finance 
Regulation 135/PMK.06/2009, which governs the position of goods and 
determination of their status. 

 
40  Skk Migas, “In 2013, role of Badan Pelaksana, including signing of coorperation 

contract, is transferred to Satuan Kerja Khusus Pelaksana Kegiatan Usaha Hulu 
Minyak dan Gas Bumi (SKK Migas)” at 58. 

41  Amir Hosein Mabadi, Legal Strategies In Upstream Oil And Gas Contracts to Attract 
Foreign Investment: Iran’s Case Shahid Beheshti University of Tehran Faculty of Law. 

42  Faizal Kurniawan, “Bentuk Perlindungan Hukum Terhadap Kekayaan Minyak Dan Gas 
Bumi Sebagai Aset Negara Melalui Instrumen Kontrak” (2013) Jurnal Prespektif 2,p 12. 

43  Simon Butt and Fritz Edward Siregar, “State Control Over Natural Resources in 
Indonesia: Implications of the Oil and Natural Gas Law Case of 2012” (2013) 31:2 J 
ENERGY Nat Resour IAW at  119. 



214 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

The task above should have consequences if, in its implementation, there 
are several goods and equipment under its supervision that are not managed 
optimally. This decision should also refer to the need and the correct 
calculation of the goods and equipment utilized or transferred to another 
party. In particular, the position of goods and equipment regulated in this 
ministerial regulation confirms the ownership of goods purchased by the 
Cooperation Contract Contractor.44 Property rights and its limitation are 
regulated in Article 570 of the Civil Code.45 

Article 570 of the Civil Code outlines that property rights are the right to 
fully enjoy an object and control that object freely, as long as not used 
contrary to laws or general regulations held by the power having the 
authority to do so.46 It does not cause interference with the rights of others. 
All of this without prejudice to the possibility of revocation of rights for the 
public interest by payment of appropriate compensation. The definition 
supports a norm outlined in Article 7 of Law 25/ 2007 on investment. 

Control over goods and equipment, which are the assets of the 
Cooperation Contract Contractor, must be followed by a clause with 
compensation or compensation. It is different from the production sharing 
cooperation contract clause, which states the rules for transferring 
ownership without also regulating compensation or compensation for the 
transfer.47 

The contract regulates the rights to equipment as executor of the use of 
goods and services in the Oil and Gas Law In particular, in the matter of 
taking over ownership of goods and equipment in this cooperation 
contract. It should regulate for appropriate compensation due to legal 
actions committed by the state against the contractor's goods and 
equipment. The basis used is that the acquisition of ownership is included 

 
44  Satryadin, Priyono & Gutami, supra note at 31. 
45  Muhammad Syahrir, “Studi Komparatif Antara Sistem Kontrak Bagi Hasil Minyak 

Dan Gas Bumi Di Indonesia Dengan Sistem KonsesI” (2011) at 170. 
46  Ibid. 
47  Andrey Hernandoko & Mochammad Najib Imanullah, “Implikasi Berubahnya 

Kontrak Bagi Hasil (Product Sharing Contract) Ke Kontrak Bagi Hasil Gross Split 
Terhadap Investasi Minyak Dan Gas Bumi Di Indonesia” (2018) at 28. 



215 | Indonesian Journal of Law and Society 

 

in the revocation of rights (onteigening),48 which requires that apart from 
the revocation of the right based on statutory regulations and public 
interest, it also states the fundamental requirements regarding appropriate 
compensation due to the legal consequences of the acquisition. Not only 
revocation of rights, legal actions committed by the state on contractor 
goods and equipment are also not based on the provisions in Article 7(1) of 
the Investment Law, which if the government takes over ownership rights. 
It must also be accompanied by compensation under market prices. 
Investor interest in seeking profit in the upstream oil industry must be 
considered. 

 

VI. CONCLUSION 

The provisions for compensation for the expropriation of ownership of 
goods and equipment of a cooperation contract must be under the market 
price as the state's responsibility respectively contractor asset's. Law 
22/2001 on Oil and Gas, Government Regulation 35/2004 on upstream oil 
and gas business activities and cooperation contracts do not regulate 
compensation clearly for the expropriation of ownership of goods and 
equipment purchased by the contractor in the agreement. The provisions 
for compensation are stipulated in the provisions for taking ownership of 
goods and equipment of investors in Article 7 of Law 25/2007 on 
investment which requires the state in this case as the parties to provide 
compensation to the contractor if the acquisition of ownership of goods 
and equipment is still desired. 
 

REFERENCES 

Abidin, Ratnasari Fajariyah. “Aspek Yuridis Renegosiasi Kontrak Karya Di 
Indonesia (Studi Kontrak Karya Antara Pemerintah Republik Indonesia 
Dengan Pt.Freeport Indonesia)” (2018) 11:01 Al-Risalah. 

 
48 Rahayu, supra note 32. 



216 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

Al-Islami, Affina Niken. “Legalitas Kontrak Kerjasama Minyak Dan Gas 
Bumi Pada Organisasi Dan Tata Kerja Satuan Kerja Khusus Pelaksana 
Kegiatan Usaha Hulu Minyak Dan Gas Bumi” 21. 

Brigita P Manohara, Ahmad Redi. “New Oil And Gas Regulations in 
Indonesia to Prevent Corruption in Upstream Sector” (2020) 7:08 J 
Critical Review. 

Chandranegara, Ibnu Sina. “Desain Konstitusional Hukum Migas Untuk 
Sebesar-Besarnya Kemakmuran Rakyat” (2017) 14:1 J Konstitusi  

Disemadi, Hari Sutra & Sahuri Lasmadi. “Utilizing Production Sharing 
Contracts (PSCs) As A Means For The Protection Of Indonesia’s Natural 
Resources” (2019) 6:3 Lentera Hukum. 

Duwi S Ariyani. “Penataan Barang Milik Negara Beleid Aset Hulu Migas 
Bikin Rumit Birokrasi”, Koran Bisniscom (Oktober 2017), Online: 
<Https://Koran.Bisnis.Com/Read/20171013/451/698733/Penataan-
Barang-Milik-Negara-Beleid-Aset-Hulu-Migas-Bikin-Rumit-
Birokrasi>. 

Dwi Atty Mardiana, Fadhlia, Ridha Husla, Rs Trijana Kartoatmodjo. 
“Assessing Indonesia’s Upstream Petroleum Fiscal Regimes Choices” 
(2019) 8:11 Int J Sci Technol Res 2449. 

Gelb, Alan, Benn Eifert & Borje Nils Tallroth. The Political Economy Of 
Fiscal Policy And Economic Management In Oil-Exporting Countries, 
Policy Research Working Papers (The World Bank, 2002). 

Genio Ladyan Finasisca, Tri Hayati. “Domestic Beneficiation Policy In 
Mining Sector : A Case Study Of Indonesia” (2020) 7:07 J Crit Rev. 

Hasan, A Madjedi. “Kontrak Pertambangan Minyak dan Gas Bumi, 
(Training on the Law of Energy and Mineral Resources)” In 
(Faculty of Law, Universitas Indonesia, 2010). 

Hernandoko, Andrey & Mochammad Najib Imanullah. “Implikasi 
Berubahnya Kontrak Bagi Hasil (Product Sharing Contract) Ke Kontrak 
Bagi Hasil Gross Split Terhadap Investasi Minyak Dan Gas Bumi Di 
Indonesia” (2018). 



217 | Indonesian Journal of Law and Society 

 

Howard R Williams, Patrick H Martin, Charles J Meyers. Manual of Oil 
and Gas Terms: Annotated Manual of Legal, Engineering and Tax 
Words and Phrases, 17 Th Edition Ed (LexisNexis). 

Huala Adolf. Dasar Dasar Hukum Kontrak Internasional (Bandung: Refika 
Aditama, 2008). 

J Satrio, Hukum Perikatan (Perikatan Pada Umumnya) (Bandung: Alumni, 
1999). 

JH Nieuwenhuis. Pokok Pokok Hukum Perikatan (Surabaya: Airlangga 
University Press, 1985). 

Kurniawan, Faizal. “Bentuk Perlindungan Hukum Terhadap Kekayaan 
Minyak Dan Gas Bumi Sebagai Aset Negara Melalui Instrumen 
Kontrak” (2013). 

Lalang Tri Utomo, Achmad Busro, Ery Agus Priyono. “Aspek Hukum 
Penerapan Asas Kekuatan Mengikat Dalam Kontrak Bagi Hasil Minyak 
Dan Gas Bumi Di Indonesia” (2016) 5:4 Dipenogoro Law Journal. 

Li, Dr Grace. “The Prc Contract Law And Its Unique Notion Of Subrogation” 
(2009) 4:1 J Int Commer Law Technol 10. 

Lubintara, Benny. “Ekonomi Migas-Tinjauan Aspek Komersial Kontrak 
Migas” In (Jakarta: Pt. Gramedia Widhasarana Indonesia, 2012). 

M Yahya Harahap. Segi Segi Hukum Perjanjian (Alumni, 1982). 

Mabadi, Amir Hosein. Legal Strategies in Upstream Oil And Gas Contracts to 
Attract Foreign Investment: Iran’s Case Shahid Beheshti University of 
Tehran Faculty of Law, 2008). 

Mckay, Jennifer & Balbir Bhasin. “Mining Law And Policy In Indonesia: 
Issues In Current Practice That Need Reform” (2001) 19:4 J Energy Nat 
Resour Law. 

Muhammad, Abdul Kadir. Hukum Perikatan (Bandung: Alumni, 1990). 

Naazneen Barma, Rents to Riches? The Political Economy of Natural 
Resource-Led Development (Washington, D.C: World Bank, 2012). 



218 | Compensation Arrangements in Expropriating Goods and Equipment: An Indonesian Experience 

 

Migas, Buletin Skk. “Membuka Harapan Baru Dari Skema Gross Split” 
(2017). 

Putuhena, M Ilham F. “Politik Hukum Pengelolaan Hulu Migas Pasca 
Putusan Mahkamah Konstitusi” (2015). 

Rahayu, Sang Ayu Putu. “Prinsip Hukum Dalam Kontrak Kerjasama 
Kegiatan Usaha Hulu Minyak Dan Gas Bumi” (2017) 32:2 Yuridika. 

R Setiawan. Pokok Pokok Hukum Perikatan (Bandung: Binacipta, 1977). 

Rudi M Simamora. Hukum Minyak Dan Gas Bumi (Jakarta: Djambaran, 
2000). 

Salim HS. Hukum Pertambangan Mineral Dan Batubara (Jakarta: Sinar 
Grafika, 2014). 

Satryadin, Maulana Arba’, Ery Agus Priyono & Budi Gutami. “Penerapan 
Asas Proporsionalitas Dalam Production Sharing Contract Pada 
Kegiatan Usaha Pertambangan Hulu Minyak Dan Gas Bumi” (2016). 

Simon Butt And Fritz Edward Siregar. “State Control Over Natural 
Resources In Indonesia: Implications Of The Oil And Natural Gas Law 
Case Of 2012” (2013) 31:2 J Energy Natural Resource Law. 

Sulaiman. “Rekonstruksi Hukum Minyak Dan Gas Bumi Yang Berkeadilan Di 
Indonesia” (2016) 18:2 Kanun Jurnal Ilmu Hukum. 

Syahrir, Muhammad. “Studi Komparatif Antara Sistem Kontrak Bagi Hasil 
Minyak Dan Gas Bumi Di Indonesia Dengan Sistem Konsesi” (2011).