Corporate taxpayers in Cambodia are classified as either resident taxpayers or non-resident taxpayers. A resident taxpayer is primarily an enterprise that has a place of management and carries on business in Cambodia, as defined below. A non-resident taxpayer is an enterprise that derives Cambodian source income but does not have a place of management in Cambodia. A non-resident taxpayer will be deemed to be a Cambodian resident for tax purposes if it is found to have a Permanent Establishment (PE) in Cambodia. A resident taxpayer is subject to Tax on Income (ToI) or Corporate Income Tax (CIT) on income derived from both Cambodian and foreign sources, whereas a non-resident taxpayer is subject to ToI/CIT in respect of its Cambodian source income only.

Our Corporate Tax team advises organisations and provides tax compliance supports on domestic and international tax laws affecting local and cross-border transactions and other regulatory matters, such as foreign investment rules and industry-specific regulatory requirements as well as domestic tax issues such as incentives, deductibility, and corporate tax management.

Why is Corporate Tax important?

Corporate tax obligations both in Cambodia and across the globe can represent a substantial outflow of funds from a business. Expanding tax reporting requirements, and increased scrutiny by tax authorities together with the imposition of penalties for non-compliance mean that the governance of tax can absorb increasing amounts of senior management time. 

Common mistakes in Corporate Income Tax calculation

  • Incorrect treatment of taxable period of income
  • Incorrect assessment of tax incentives
  • Over-claimed deductible expenses
  • Insufficient supporting documents for expenses
  • Unclear/incorrect documentation related to cross-border transactions
  • Inappropriate allocation of expenses among related parties
  • Incorrect claim of tax losses carried forward
  • Incorrect claim of deductible interest expenses or interest carried forward
  • Incorrect treatment of promotional expenses

It is, therefore, important that you have access to the right advice and compliance support at the right time to enable you to achieve effective tax compliance and manage tax risks, whilst also controlling costs.


In Cambodia, our teams are organised based on lines of business, which allows us to understand your needs through our collective experience of the issues you face. Our industry-focused approach can help you with a wide range of corporate tax planning and compliance issues

We maintain regular and constructive dialogues with the Cambodian government and local networks to enable us to assist you effectively and when needed.

We will work closely with you to provide practical, useful ideas based on a deep understanding of your specific tax issues.

KPMG can offer a global-local perspective on the issues you face.  We understand local and international tax regimes and have access to the international resources and experience needed to help you achieve tax-effective business outcomes, wherever you do business.

How can KPMG help?

Our CIT or ToI services include:

  • CIT Preparation and Compliance Management  
  • CIT Review Prior To Filing
  • Deferred Tax Calculation
  • CIT Planning and Advisory
  • Historical CIT Compliance Review 
  • Tax Incentive Request
  • Inter-company transactions review
  • CIT Compliance Training
  • Seeking Tax Ruling


Connect with us

More from KPMG