Law Number 16 of 2009 concerning General Provisions and Tax Procedures (UU KUP), regulates administrative sanctions and criminal sanctions. The KUP Law method does not yet regulate how to save the loss of state revenue because it does not regulate the implementation of criminal fines, the legal implications of different decisions that cause legal uncertainty, injustice and have not provided benefits, especially in an effort to collect taxes. The purpose of this paper is to find out, analyze, and find the urgency of regulating criminal sanctions for the deprivation of assets in tax crime. This study is normative legal research with a legislation approach, historical approach, comparative law approach, conceptual approach, and case approach. The legal materials used are primary and secondary legal materials. Analysis of legal material is done with a descriptive perspective. The results of this study indicate that the inclusion of fine sanctions in the KUP Act turns out to lead to different interpretations resulting in legal uncertainty and does not provide economic benefits for the state in law enforcement, because the sanctions for fines are not complemented by implementing sanctions in the form of additional criminal sanctions in the form of confiscation of assets belonging to the defendant or an act (maatregel) in the form of requiring improvement of corporate governance in accordance with good corporate governance or placement of a legal company, where an economic crime is committed under a certain period of time, so that in the future the KUP Act, additional sanctions or actions to strengthen / complete in the future criminal sanctions for fines.

S tates engaged in economic activities in order to achieve the goals of the state. Law Number 17 of 2003 on S tate Finance states that the form of state activity in economic activity is conducted through a state enterprise, known as a S tate-Owned Enterprise in the form of a Persero regulated in Law Number 19 Year 2003 concerning BUMN, stating that the BUMN of a whole business entity or most of the capital is owned by the state through direct inclusion derived from separated state assets. Persero, is a state-owned limited liability company whose capital is divided into shares wholly or at least 51% (fifty one percent) of its shares owned by the Republic of Indonesia whose main purpose is to pursue profit. BUMN is PT. To strengthen the capital structure and increase the capacity of the Company's business PT Persero Aluminum Limited is determined through Government Regulation Number 47 Year 2017 on Addition of S tate Equity Participation of the Republic of Indonesia Into S hares of Limited Liability Company PT Indonesia Asahan Alumunium, acting as the parent Company in the field of mining. Several laws governing S tate-Owned Enterprises in their implementation create a sense of confidence for the Board of Directors of the Company in driving its business in case of loss. The polemic that arises is how the legal status of state equity participation of state assets separated on state-owned company Persero case study on PT Inalum as the holding company holding the mining field? Business is risk. In the event of any loss in the business process of PT Inalum, does the loss include the state loss domain or the loss of the business? Through normative legal research the researcher will do the research.