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BUT (Badan Usaha Tetap) or so called as PE (Permanent Establishment) has been applied for decades as a basic regulation for tax withdrawal to multinational companies who operate in Indonesia. The definition itself has been written down in Indonesia-s constitution law -UUD 1945. However, due to technology disruption that allow global companies not to present physically in a home country, the definition of PE is questionable. Even though, PE has been redefined couple months ago by Indonesian government, the issue of Base Erosion and Profit Sharing (BEPS) has not been completely stated. In fact, BEPS is utilized globally for tax avoidance. This study will focus to Over The Top (OTT) companies which grow systematically rapid these days, operate and gain income globally. Among all OTT companies, this study will dig deeper to the most present company among all OTTs which is Google Asia Pacific. This qualitative research results a develop model to PE regulation in Indonesia and re-redefine PE to be able to cover and limit BEPS practice and in the end increasing Indonesia-s tax admission.