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 disincentives to investment. Many companies have not yet fully considered […]

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 a dividend distribution, and thus subject to WHT. Readers should be reminded that, […]

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 in accordance with the OECD’s guidelines. The regulations left many questions unanswered, […]

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 promote a fair and competitive business environment. The three types of […]

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 the GDT issued Instruction Letter 4909, which states that taxpayers […]

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 February 2019, the RGC issued Sub-Decree No. 33 ANK.BK (on the […]

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 in accordance with the OECD’s guidelines. The regulations left many questions unanswered, […]

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 and procedures related to the recognition of a principal-agent relationship, and the value added tax (“VAT”) […]

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”. On 6 September 2018 the General Department of taxation (“GDT”) issued Notification 12802, entitled “Textile and Garment Enterprises’ Voluntary […]

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 loan agreement is registered with the […]

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 follows: Will it be possible to obtain the GDT’s […]

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 a Royal Decree on 9 December 2017 announcing that the parties to […]