Cambodia Poised to Clarify Profit Attribution and Transfer Pricing of Cross Border Shipping Income

The determination and taxation of the Cambodian sourced income of international shipping liners has long posed problems in this dynamic Southeast Asian country. As a longstanding manufacturing hub, imports of raw materials and export of finished and semi-finished products are hallmarks of Cambodia’s robust economy. However, the taxation of shipping lines has been an area of uncertainty and concern for many years. This was not alleviated when Cambodia introduced transfer pricing (“TP”) in 2017 by means of Prakas 986.