Andrea Godfrey
Partner
Head of Integrated International Tax
KPMG in Cambodia
Andrea Godfrey
Partner, Head of Integrated International Tax, KPMG in Cambodia
Andrea is a very experienced tax professional having worked in both practice and industry over a period of 35 years. She has a particular focus on global cross border transactions and projects working in the Infrastructure and Construction sector for 12 years and was part of the E&C sector leadership team in her previous role at EY UK&I.
Andrea has extensive experience in putting together teams to provide the most relevant expertise for clients needs and prides herself in being seen as a trusted advisor to her clients. She led the first large Corporate tax compliance outsourcing contract for EY UK&I utilizing and managing resource in the UK and India and building the basis for the development of the CIT compliance process. Andrea joined KPMG in Cambodia and Vietnam in November 2017 to enhance global delivery service of the tax practice working alongside highly experienced Cambodia and Vietnamese tax professionals in a rapidly evolving environment.
She took over the Global Mobility Services (GMS) team in October 2018, building the team and integrating into the Global GMS practice and was a Speaker on many related topics. Andrea moved to Cambodia in January 2024 to work with the international tax team bringing her experience in tax encompassing M&A, financing of major projects, permanent establishment and international supply chain risk including transfer pricing and tax compliance outsourcing projects.
Selected Experience:
So Dary
Partner
Head of Corporate Services
KPMG in Cambodia
So Dary
Partner, Head of Corporate Services, KPMG in Cambodia
Dary is a partner of a tax Practice, Corporate Services, Customs & Trading at KPMG in Cambodia. Dary has more than 18 years of experience advising and assisting clients to conduct trouble free business in Cambodia.
Dary has a diverse experience and works with clients across numerous business functions to ensure compliance with the laws and regulations in Cambodia. Dary oversees KPMG’s tax and corporate services and manages the delivery of a range of business solutions to clients which include:
- Taxes compliance and tax health check review
- Tax due diligence
- Tax advice on restructuring and tax planning strategy
- Accounting & Financial Management services
- Corporate governance and risk management
03 July 2025
By Andrea Godfrey & So Dary, KPMG in Cambodia
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As global trade tensions rise, Cambodia’s export-oriented economy faces fresh pressure from a wave of tariff increases, most notably from the United States. While much of the focus has been on direct impacts such as higher costs and reduced competitiveness, experts now warn of deeper implications tied to transfer pricing (TP)—and a growing risk of tax disputes if businesses don’t adapt quickly.
Cambodia’s Strategic Position in Global Supply Chains
Cambodia has become a crucial manufacturing hub for multinational corporations in sectors like electronics, apparel, and consumer goods. With a strong export base and increasing integration into global value chains, the country is particularly sensitive to sudden changes in trade policy.
Short-Term Shocks vs Long-Term Shifts
| Short-Term Impacts | Long-Term Considerations |
|---|---|
| Sudden cost spikes due to new tariffs | Possible relocation of supply chains |
| Disrupted U.S. orders or thinner margins | Diversification to non-U.S. markets |
| Quick fixes like rush shipments or price hikes | Need for reinvestment and new buyers |
| Outdated TP arrangements | Fresh pricing logic and documentation needed |
One common example: A Cambodian subsidiary sells to its U.S. parent company. With Cambodia tariffs in place, should the Cambodian entity lower its prices to maintain competitiveness? Or should the U.S. side absorb the extra cost? Either choice affects where the profit—and tax liability—lands.
Why Transfer Pricing Now Matters More Than Ever
Transfer pricing, which governs how profits are allocated among related entities in different countries, is coming under intense scrutiny. Tariffs reduce total profits, and tax authorities—both in Cambodia and abroad—are closely watching how those profits are shared.
In Cambodia, tax officials may challenge exporters who report lower margins due to tariffs, especially if there's no supporting documentation. If foreign authorities take a different view, businesses may face double taxation—a situation where the same income is taxed in two countries.
Documentation: The First Line of Defense
Cambodian tax authorities have already been ramping up TP audits in recent years. Tariff-induced profit drops or pricing changes will trigger even closer reviews.
Companies should act now to:
- Clearly document why prices changed (e.g., new tariffs, supply shifts)
- Run scenario analyses to explain how costs and profits are shared
- Consider Advance Pricing Agreements (APAs) to lock in treatment with key trade partners
Practical Steps for Cambodian Exporters
| Action | Why It’s Important |
|---|---|
| Re-evaluate TP policies | Align with current costs and profit pressures |
| Strengthen TP documentation | Avoid disputes and defend pricing structures |
| Monitor global tariff changes | Prepare for future cost and price volatility |
| Explore bilateral APAs | Reduce risk of double taxation |
Looking Ahead
Cambodia’s integration into global trade is a strength—but also a vulnerability. As geopolitical and economic uncertainties grow, exporters must not only navigate cost pressures, but also adjust their internal pricing strategies to stay compliant and competitive.