Tax Updates

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 […]
18
Oct
2017
Special Client Alert: Transfer Pricing Part 3
      TRANSFER PRICING PART 3 In our third Special Client Alert on Transfer Pricing, we look at the process of selecting the most appropriate transfer pricing method, and discuss what documentation you will need to have.   Key Takeaways If you have transactions with a related party (parent or sister company) you will […]
12
Oct
2017
Cambodia Tax Alert: Changes in Public Lighting Tax and clarification on tax incentives for SMEs
      CHANGES IN PUBLIC LIGHTING TAX AND CLARIFICATION ON TAX INCENTIVES FOR SMES Public Lighting Tax changes On 9 October 2017, the Ministry of Economy and Finance (“MOEF”) issued Prakas No. 976.MEF.Prk, a new Prakas on Public Lighting Tax (“PLT”) that supersedes the previous Prakas on PLT. PLT applies on the supply of […]
10
Oct
2017
Special Client Alert: Transfer Pricing Part 2
      TRANSFER PRICING PART 2 In this, our second Special Client Alert on Transfer Pricing, we review the five methods acceptable under the OECD Guidelines for determining the arm’s length price of related party transactions.   Key Takeaways There are 5 acceptable transfer pricing methods under the OECD Guidelines 3 traditional transaction methods […]
27
Sep
2017
Look Out, Transfer Pricing Is Coming!
LOOK OUT, TRANSFER PRICING IS COMING! This is the first in a series of 4 Special Client Alerts aimed at giving you a heads-up on what this means for your business, and what you should do now to prepare for it! Key Takeaways Issuance of transfer pricing regulations in Cambodia is imminent Regulations are modeled […]
18
Aug
2017
Cambodia Client Alert: Now it’s a hat trick of DTAs!
On 27 July 2017 representatives of the governments of Brunei and Cambodia signed Cambodia’s third Double Taxation Agreement (“DTA”). Brunei and Cambodia have good diplomatic relations, and Brunei is a significant customer for Cambodian rice exports. Perhaps this DTA will encourage additional trade and investments between the two Kingdoms. What does this DTA mean for […]
19
Jul
2017
Cambodia Tax Alert: Exemption from Minimum Tax
The2017 Financial Law, has revised Article 24 of the Law on Taxation (“LOT”) to the following: “Minimum tax is determined to be equal to 1% of annual turnover inclusive of all taxes except value added tax. The minimum tax payable for any taxable year may be reduced by the annual tax on income that is […]
22
May
2017
Cambodia Client Alert: Conversion of Retained Earnings to Capital
In Cambodia, there has always been a question regarding the tax treatment and implications of the conversion of retained earnings to capital. There has been inconsistent interpretation and handling of this tax issue, both between taxpayers and tax officers, and among the tax officers themselves, due to unclear tax provisions. Taxpayers are of the view that the […]
6
Apr
2017
VDB Loi Cambodia Client Alert: Extension of filing deadlines and good news for schools!
On 31 March 2017 (the last date for the filing of annual tax returns for those with a 31 December year-end) the General Department of Taxation (“GDT”) made the dramatic last minute announcement  that the deadline was being extended. The extended deadline for filing the 2016 Tax on Profit (“TOP”) return is now 30 April […]
23
Jan
2017
Cambodia Client Alert: Waiver of penalties on amended tax returns
On 19 January 2017 the GDT issued Notification Letter No. 1219 regarding the Waiver of Penalties for the Voluntary Amendment of Tax Returns. Many of you will be aware that in recent times it has been very difficult to obtain a reduction in penalties following a reassessment, as part of the penalties collected are distributed […]
10
Nov
2016
Cambodia Client Alert: China-Cambodia DTA
On 13 October 2016 representatives of the governments of the People’s Republic of China and Cambodia signed Cambodia’s second Double Taxation Agreement (DTA) during the visit of Chinese President Xi Jinping. Cambodia’s first DTA was signed with Singapore in May of this year. The new DTA is important as China is already a significant investor […]
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