Tax Updates

7
May
2019
Client Alert: Tax treatment of seniority payments clarified and VAT exemption on recruiting and training fees
      CLIENT ALERT: TAX TREATMENT OF SENIORITY PAYMENTS CLARIFIED AND VAT EXEMPTION ON RECRUITING AND TRAINING FEES   On 11 April 2019, the Ministry of Economy and Finance issued Circular 003 to confirm the tax treatment of seniority payments introduced by a 2018 amendment to the Labor Law and the issuance of Prakas […]
30
Apr
2019
Special Client Alert: Tax Saving Opportunities
      SPECIAL CLIENT ALERT: TAX SAVING OPPORTUNITIES   The Royal Government of Cambodia has been working hard to stimulate investment and economic growth. The General Department of Taxation (“GDT”) is playing an important role in this process and many new tax regulations and procedural changes have been introduced to improve transparency and eliminate […]
22
Apr
2019
Client Alert: Important Update on Withholding Tax on Dividends
      CLIENT ALERT: IMPORTANT UPDATE ON WITHHOLDING TAX ON DIVIDENDS   On 5 April 2019, the Ministry of Economy and Finance issued Prakas 372 to introduce new rules on dividend withholding tax (“WHT”). This Prakas replaces Prakas 518, which was issued on 5 May 2017, and expands the definition of what is considered […]
12
Apr
2019
Client Alert: Tax Audit – Important Update!
      CLIENT ALERT: TAX AUDIT – IMPORTANT UPDATE!   On 13 March 2019, the Ministry of Economy and Finance (“MEF”) issued Prakas 270 on Tax Audits (“Prakas 270”), which attempts to streamline the tax audit process, as part of the government’s large-scale economic reforms, to improve transparency in tax payments and collections, and […]
3
Apr
2019
Client Alert – Update on Interest-Free Loans
      CLIENT ALERT: UPDATE ON INTEREST-FREE LOANS   In a recent Client Alert, we advised that the General Department of Taxation (“GDT”) had verbally indicated that interest-free loans between related parties would again be permitted after having been “banned” following the issuance of the transfer pricing regulations (Prakas 986). On 18 March 2019 […]
14
Mar
2019
Cambodia Tax Alert: Additional Incentive for Qualified Investment Project
        ADDITIONAL INCENTIVE FOR QUALIFIED INVESTMENT PROJECTS   As seen recently, the Royal Government of Cambodia (“RGC”) has been making a number of improvements in the investment regime in order to attract more investors and encourage existing investors to continue and/or expand their business operations in Cambodia. To this end, on 13 […]
12
Mar
2019
Breaking news: Interest-free loans, an update
      BREAKING NEWS: INTEREST-FREE LOANS, AN UPDATE   As you are all aware, following the introduction of Prakas 986 (the transfer pricing regulations), Instruction Letter 151, which permitted interest-free loans between related parties, was withdrawn, and under Instruction 11946, such loans were required to bear interest. On 7 March 2019, at a meeting […]
5
Feb
2019
Cambodia Client Alert: Double Taxation Agreements – Latest Developments
      DOUBLE TAXATION AGREEMENTS – LATEST DEVELOPMENTS   In December 2018, the Royal Government of Cambodia announced that Double Taxation Agreements (“DTAs”) had been signed with Vietnam and Indonesia, bringing the number of DTAs signed by Cambodia to six. It was also announced that with effect from 1 January 2019, the DTAs signed […]
30
Jan
2019
What Happened in Cambodia While You Weren’t Looking
      What Happened in Cambodia While You Weren’t Looking   Financing and tax 2018 saw several changes to the tax regulations. The application of transfer pricing rules in Cambodia is now a reality. Starting from 2018, companies have to comply with the regulations issued in October 2017, which adopt the arm’s length principle […]
28
Jan
2019
Cambodia Client Alert – Transfer Pricing: Related Party Loans
      TRANSFER PRICING: RELATED PARTY LOANS   On 21 August 2018, the General Department of Taxation (“GDT”) issued Instruction 11946 to clarify its position with respect to the applicability of Prakas 9986 (the transfer pricing (“TP”) regulations) to interest-free loans between related parties. Since 2014, Instruction 151 had permitted loans from related parties […]
4
Oct
2018
Cambodia Client Alert: New Prakas on Principal-Agent transactions, of particular interest to the FMCG industry
      NEW PRAKAS ON PRINCIPAL-AGENT TRANSACTIONS, OF PARTICULAR INTEREST TO THE FMCG INDUSTRY   On 27 June 2018, the Ministry of Economy and Finance issued Prakas 597 entitled “Recognition and some Tax Obligations of Agents Supplying Goods or Services on behalf of a Principal Enterprise”, the stated objective of which is to establish the rules […]
27
Sep
2018
Cambodia Client Alert: Interesting developments for the garment, footwear, and bags industry…..and some challenges!
          INTERESTING DEVELOPMENTS FOR THE GARMENT, FOOTWEAR, AND BAGS INDUSTRY…..AND SOME CHALLENGES!   On 3 August 2018 the Ministry of Economy and Finance issued Prakas 741, entitled “Rules and Procedures for the Implementation of Tax on Income and Other Taxes Related to the Cut, Make and Trim Activities of Qualified Investment Projects”. […]
24
Aug
2018
Cambodia Client Alert: Interest-free loans
      INTEREST-FREE LOANS   In an earlier client alert your attention was drawn to the likely impact of Prakas 986 (the transfer pricing regulations) on the continued applicability of the General Department of Taxation’s (the “GDT’s”) Instruction 151 which, since 2014, has permitted loans from related parties to be interest-free, if the related […]
22
Jun
2018
Cambodia Tax Alert: Transfer Pricing – Important New Developments!
      TRANSFER PRICING: IMPORTANT NEW DEVELOPMENTS!   VDB Loi have recently had the opportunity to meet senior members of the GDT’s Transfer Pricing team to discuss and clarify certain issues that are not clearly addressed in the new Transfer Pricing (“TP”) regulations. These issues, and the GDT’s current thinking on them, are as […]
24
Jan
2018
Cambodia Tax Alert: DTAs with Singapore and Thailand now in effect
      DTAS WITH SINGAPORE AND THAILAND NOW IN EFFECT   Last week the General Department of Taxation (“GDT”) issued a press release to confirm that the Double Taxation Agreements (“DTAs”) signed in 2016 and 2017 between Cambodia and Singapore, and Cambodia and Thailand, respectively, became effective 1 January 2018, following the issuance of […]
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