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Tax Update: Notification No.004 MEF.S.C.N on The Additional Property Tax Incentives for Stalled Building Projects in Preah Sihanouk Province

Posted on July 16, 2025

On 23 April 2025, the Ministry of Economy and Finance issued Notification No. 004 MEF.S.C.N on Additional Incentives for Property Tax, officially extending the property tax exemption for stalled building projects in Preah Sihanouk Province until 31 December 2028. This measure falls under the framework of the “Special Program to Promote Investment in Preah Sihanouk Province 2024.” The extension of the property tax exemption applies to building projects that commenced in 2016 or later, regardless of their construction progress, whether completed or not by 2025, and irrespective of whether the project is formally registered under the Government’s investment promotion framework. It’s important to note that this extension of incentives does not apply retroactively to taxes or administrative penalties that have been paid.

About the Special Program to Promote Investment in Preah Sihanouk Province 2024

The Special Program to Promote Investment in Preah Sihanouk Province 2024 was launched by the Royal Government in January 2024. The program was created to respond to widespread construction delays and economic stagnation in the province. Its goal is to revive investment confidence, complete unfinished developments, and attract new capital to key sectors such as real estate, tourism, manufacturing, and environmental infrastructure.

The Special Program to Promote Investment in Preah Sihanouk Province 2024 targets three types of eligible projects: (1) investment projects or business activities related to stalled or unfinished buildings that began in 2016 or later and are set to resume implementation in 2024; (2) new investment projects or business activities not related to unfinished buildings, but commencing in 2024; and (3) expansion of existing investment projects or business activities that meet specific criteria and will begin in 2024. Projects outside this scope, including those in banking, finance, or beverage sectors (except for those using agricultural products), are not eligible for incentives under this program.

To encourage investment in these categories, the program offers a range of tax incentives. These include exemptions from income tax, minimum tax, and the prepayment of income tax; application of zero-rated value-added tax for the supply of domestic goods and services used in construction; a five-year exemption from withholding tax on rental income; and an exemption from annual property tax and related administrative penalties.

According to the General Department of Taxation’s Newsletter No. 107, as of April 2025, the Investment Promotion Working Group in Preah Sihanouk Province has approved, in principle, incentives for a total of 287 investment projects, representing an estimated total investment capital of approximately USD 6.875 billion and are estimated to have generated around 2,916 jobs. These figures highlight the growing impact of the Special Program to Promote Investment in Preah Sihanouk Province 2024 in stimulating economic activity, accelerating project implementation, and reinforcing investor confidence in the province.

This tax update is brought to you by Davies SM Attorneys-at-law.

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