Cambodia: Approved treaty benefits effective for full calendar year
The General Department of Taxation issued instruction clarifying validity of benefits under income tax treaties
The General Department of Taxation (GDT) issued Instruction no. 180 GDT (dated 3 January 2024) clarifying that the validity of benefits under income tax treaties are, in all cases, effective for one year from 1 January of the current tax year.
Taxpayers must apply for treaty benefits and achieve full compliance with the relevant tax laws and regulations before receiving approval from the GDT.
KPMG observation
Previously, for first-time applications, treaty benefits were generally effective from the date of approval up to the end of the calendar year. Thus, taxpayers were not able to fully enjoy the treaty benefits if the treaty certificates were granted during the later part of the year. This new instruction will allow taxpayers to avail of the treaty benefits for a full year once approval is granted by the GDT. However, taxpayers may need to revisit, and if needed, amend the tax declarations that were filed prior to obtaining approval to apply the treaty benefits.
Read a February 2024 report [PDF 189 KB] prepared by the KPMG member firm in Cambodia