Cambodia: Updated guidance on income tax, various indirect taxes

The Ministry of Economy and Finance (MoEF) issued a new Prakas on income tax (Prakas No. 578 MEF.Prk.GDT (September 19, 2024)) to update certain provisions to align with the 2023 New Law on Taxation, including provisions relating to:

• Definition of permanent establishment (PE)
• Tax year
• Source of income
• Research and development (R&D) expenses
• General rules of withholding tax
• Minimum tax
• Exemption from advanced tax on dividend distributions (ATDD)
• Tax on income of foreign branches

Prakas 578 is effective from January 1, 2025, and supersedes the old Prakas on income tax (Prakas No. 98 (January 29, 2020)).

In addition, the General Department of Taxation (GDT) released standard operating procedures (SOPs) for the following taxes:

• Tax on means of transportation
• Tax on property rental
• Real property tax
• Stamp tax
• Tax on unused land

The SOPs outline the rules and procedures for the declaration and payment of the taxes, including provisions on purpose, definition, tax rate/payable for each type of transaction, and the transactions exempt from tax.

Read a March 2025 report prepared by the KPMG member firm in Cambodia summarizing the key changes in and implications of the new guidance.