Cambodia: Guidance on documentation for loans between related parties, taxation of trusts, reduced withholding tax on payments by airlines to nonresidents

Recent guidance issued by General Department of Taxation (GDT)

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June 5, 2025

The General Department of Taxation (GDT) issued Instruction no. 14256 GDT (dated May 12, 2025)—further to the issuance of the new transfer pricing Prakas 574 (dated September 19, 2024)—to clarify the necessary supporting documents for interest on loans between related parties.

In addition, the GDT issued Prakas No. 192 MEF.Prk.GDT (dated and effective March 12, 2025) providing rules and procedures on taxation of trust, and Prakas no. 198 MEF.Prk.GDT (dated March 17, 2025) confirming the reduced withholding taxes on payments made by domestic airline companies to nonresident taxpayers. 

Read a June 2025 report prepared by the KPMG member firm in Cambodia

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