Market Info

Businesses are required to pay PT upon business registration and every year thereafter for each business activity that they carry out.

In previous years the Government fee required to obtain a PT Certificate was approximately USD 285. The revised PT fees are as follows:

1. Small Taxpayer KHR 400,000 / USD 100
2. Medium Taxpayer KHR 1.2 million / USD 300
3. Large Taxpayer KHR 3 million or KHR 5 million* USD 750 or USD 1,250

*If the annual turnover of the Large Taxpayer exceeds KHR 10 billion (USD 2.5 million) then the PT payable will be USD 1,250. If the annual turnover of the Large Taxpayer is less than KHR 10 billion (USD 2.5 million) the PT payable will be USD 750.

The PT must be paid at the place where taxpayers have their specific/real business operation. A taxpayer which has a branch office, warehouse, factory and workshop with the same business objective in the same location (city-province) must only pay one PT fee.

Source: https://www.dfdl.com/resources/publications/investment-guides/cambodia-2020/

The ST is imposed on a number of local and imported products and services. The rates range from 3% to 45%. Goods subject to this ST include soft drinks, alcoholic beverages, cigarettes, and certain services such as entertainment, domestic and international air tickets, and telephone services.

Source: https://www.dfdl.com/resources/publications/investment-guides/cambodia-2020/

Tax penalties are imposed for violations of the LOT and its regulations. The level of the penalty depends upon the nature of the violation, and is determined as follows:

• Where a taxpayer or withholding agent is considered negligent (the amount of deficient tax paid is 10% or less than the amount of taxes due) the penalty is 10% of the unpaid tax;
• Where a taxpayer or withholding agent is considered seriously negligent (the amount of deficient tax is more than 10% of taxes due) or the taxpayer has failed to settle tax liabilities by the due date as stated in a tax notification on late payments issued by the GDT, the penalty will be 25% of the unpaid tax; and
• Where a tax audit conducted by the GDT exposes an underpayment of taxes, the penalty will be 40% of the unpaid tax.

In addition, penalties are imposed for late payment of taxes and late lodgment of returns, together with interest charged at 1.5% per month.

Source: https://www.dfdl.com/resources/publications/investment-guides/cambodia-2020/

Cambodia has signed Agreements for the Avoidance of Double Taxation (“DTAs”) with Singapore, China, Brunei, Thailand, Vietnam, Indonesia and Hong Kong. The DTA with Singapore and Thailand came into force on 1 January 2018 and those with China, Brunei and Vietnam entered into force on 1 January 2019. DTAs are expected to reduce barriers on cross-border investment and trade between the countries, along with the fostering of heightened future economic growth in Cambodia. Of note is the reduction in the standard WHT rates for payments made to non-residents whereby the standard Cambodian WHT rate of 14% with respect to payments of interest, royalties, service fees and dividends are reduced to 10% in most cases for those taxpayers who qualify and obtain approval from the GDT under the DTA.

Source: https://drive.google.com/file/d/1ZsnUB3DiybFaGG2FOmBZNWtVd6pVTF-M/view?usp=sharing

Withholding tax in Cambodia needs to be withheld on payments made by residents (and it seems only to those who fall under the self-declaration regime). The withheld tax constitutes a final tax when withheld in respect of resident and non-residents. The types of payments caught are as follows. WHT on payment to residents Interest: 15% (except payment to a Cambodian-registered bank or financial institution). Royalties: 15%. Rental: 10%. Interest (except local bank and financial institutions): 15%* Interest for fixed deposit: 6%* Interest for saving deposit: 4%* Services: 15% (except payments to a registered taxpayer and supported by a valid VAT invoice). WHT on payment to non-residents Under the Law on Financial Management 2017, which is effective from 1 January 2017 onwards, any resident taxpayer carrying on a business, including a PE of a non-resident person, who pays any Cambodian-source income as defined under Article 33 of the Law on Taxation to a non-resident taxpayer must withhold tax at 14% of the amount paid. WHT does not apply to property or risk reinsurance premiums in Cambodia. According to Article 33 of the Law on Taxation, Cambodian-source income includes: Interest paid by a resident enterprise, resident pass-through, or a governmental institution of Cambodia. Dividends distributed by a resident enterprise. Income from services performed in Cambodia. Compensation for management and technical services paid by a resident person. Income from movable or immovable property, if the property is situated in Cambodia. Royalties from the use, or right to use, intangible property paid by a resident person or paid by a non-resident person through a PE maintained in Cambodia. Gain from the sale of immovable property located in Cambodia or from the transfer of any interest in immovable property situated in Cambodia. Premiums from the insurance or reinsurance of risks in Cambodia. Gain from the sale of movable property that is part of a PE’s business property maintained by a non-resident taxpayer in Cambodia. Income from business activities conducted by a non-resident through a PE in Cambodia. WHT is due when the amount is paid. An expense is considered ‘paid’ when it is recorded in the accounting records. Except WHT on the rental of movable and immovable properties as stated in Article 25 and 26 of the Law on Taxation, small taxpayers are exempted from being the WHT agents for other WHT implications. * The data is from Deloitte tax guide 2020, page 20.

Source: https://taxsummaries.pwc.com/cambodia/corporate/withholding-taxes