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DFDL | May 2023

Overview On the 16th of May 2023, the New Law on Taxation (“New Taxation Law”) was promulgated by Royal Kram No. NS/RKM/0523/004. The New Taxation Law abrogates the Law on Taxation, promulgated by Royal Kram No. NS/RK/0297/03, dated February 24, 1997 (“Former Taxation Law”), and the Law on Amendment to the Law on Taxation, promulgated by Royal Kram No. NS/RK/0303/010, dated March 31, 2003 ...

DFDL | July 2018

It is fair to say that one of most consistent complaints we hear from taxpayers regards the issues associated with applying and obtaining a Value Added Tax (VAT) refund in Cambodia. Until now the VAT refund process was a very lengthy process – sometimes taking years – and often subject to uncertainty and delays ...

DFDL | September 2019

Cambodia has signed a Double Taxation Agreement (“DTA“) with Malaysia on the 3rd of September 2019 during the visit of Malaysian Prime Minister Tun Dr Mahathir Mohamad to Phnom Penh. Under the DTA, double taxation will be avoided in that any tax paid in Cambodia by Malaysian companies in accordance with the DTA will be allowed as a credit against the tax payable in Malaysia on the same income, subject to the provisions of the tax laws of Malaysia ...

DFDL | June 2020

On 26 May 2020, the Royal Government of Cambodia (“RGC”) issued a press release and rolled out round 4 of measures aimed at mitigating the impact of COVID-19 on the businesses and workers in Cambodia. These latest measures consist of a combination of new measures and extension of those measures already in place ...

DFDL | September 2020

We would like to take this opportunity to remind our readers that the immovable property tax (“TOIP“) and Unused Land Tax deadline for 2020 is next Wednesday the 30th of September 2020. The 2020 TOIP and Unused Land Tax payment can be made at any tax branch or any branch of Canadia, Acleda, Vattanac or Cambodia Public Bank. Those already registered for TOIP and Unused Land Tax need to provide their 2019 tax payment receipt or Property Tax Registration Identification Card ...

DFDL | September 2021

We would like to take this opportunity to remind our readers that the immovable property tax (“TOIP”) and Unused Land Tax deadlines for 2021 are fast approaching next Thursday (the 30th) of September 2021. The 2021 TOIP and Unused Land Tax payment can be submitted at any tax branch or any branches of the following banks: Canadia, ACLEDA, Vattanac, Cambodia Public Bank or ABA Bank ...

DFDL | September 2021

Following our recent update on the due date of 30 September 2021 for the declaration and payment of the 2021 Immovable Property Tax (“TOIP“) and Unused Land Tax we would like to inform our readers that on the 28th of September 2021 the General Department of Taxation (“GDT“) issued Notification 16160 which has provided an extension on the deadline of the declaration and payment tax of TOIP for 2021 until 31 October 2021 ...

DFDL | February 2022

With the 2022 year well under way most enterprises in Cambodia are turning their attention to their annual compliance obligations. There have been some recent changes and updates with respect to the annual compliance obligations for most enterprises in Cambodia. We have included the recent changes in our summary below ...

DFDL | March 2022

The General Department of Taxation (“GDT”) issued Notification no. 4577 GDT on the 9th of March 2022 (“Notification 4577”) which delays the implementation of Prakas 346 MEF.P on Capital Gains Tax (“Prakas 346”) to 1 January 2024. Previously Instruction 24094 issued by the GDT on the 9th of October 2020 (“Instruction 24094”) had postponed the implementation of Prakas 346 to 1 January 2022 ...

DFDL | February 2022

On 10 February 2022, the General Department of Taxation (“GDT”) issued Notification 2845 (“Notification 2845”), which provides the 2021 market interest rates for Employee Loans in accordance with Article 15 of Prakas 543 on Tax on Salary and Instruction No. 7015 GDT dated 13 March 2020. The 2021 market interest rates for 2021, based on the average of ten (10) commercial Cambodian banks, are as follows: USD – 8.28% per annum Khmer Riel – 8 ...

DFDL | November 2022

Instruction No. 27185 GDT (“Instruction 27185”) on the Display of Tax Registration Documents at Business Premises was issued by the General Department of Taxation on the 14th of November 2022 ...

DFDL | January 2022

The General Department of Taxation (“GDT”) issued Notification no. 776 GDT on the 17th of January 2022 (“Notification 776”) which delays the implementation of Prakas 542 MEF.P on the Rules and Procedure for the Implementation of VAT on E-Commerce (“Prakas 542”) to 31 March 2022 ...

DFDL | April 2021

Notification no. 7175 GDT dated 16 April 2021 (“Notification 7175”) from the General Department of Taxation (“GDT”) provides an extension of the due date for the March 2021 monthly tax returns and payment. Key Takeaway For taxpayers whose businesses are prohibited to operate under Decision No. 49 the deadline for the March 2021 monthly tax payment and return submission has been extended to 15 May 2021 ...

DFDL | February 2021

On 14 January 2021, the Ministry of Economy and Finance issued Prakas No. 010 on “the Local Manufacturers Obligation to place devices for measuring the volume of beer and non-alcoholic drinks” (“Prakas 010”). The purpose of Prakas 010 is to establish rules and procedures for managing the use of devices which measure the volume of beer, and/or non-alcoholic beverages that are produced locally ...

DFDL | February 2021

On 14 January 2021, the Ministry of Economy and Finance issued Prakas No. 010 on “the Local Manufacturers Obligation to place devices for measuring the volume of beer and non-alcoholic drinks” (“Prakas 010”). The purpose of Prakas 010 is to establish rules and procedures for managing the use of devices which measure the volume of beer, and/or non-alcoholic beverages that are produced locally ...

DFDL | April 2021

Notification no. 7179 GDT dated 18 April 2021 (“Notification 7179”) from the General Department of Taxation (“GDT”) provides procedures for the submission of scanned application forms, administrative letters, other documents or tax returns to the GDT, including tax branches in Phnom Penh and the provinces, via online (E-Document Submission System) ...

DFDL | September 2021

Key points From 8 September 2021 non-resident entities who provide digital goods/services or e-commerce activities to Cambodian consumers and who expect to have sales of USD15k or more before the end of the year, over three consecutive months, have 30 days to register for VAT with the General Department of Taxation (GDT) in Cambodia. From 2022 onward the same non-resident entities, as described above, that expect to have sales of USD62 ...

DFDL | April 2021

Pursuant to the Prakas on Launching the Use Rules and Procedures of Bakong System dated 26 June 2020 and the Prakas on Management of Payment Service Providers dated 14 June 2017, the National Bank of Cambodia (“NBC”) has determined transaction amounts and KYC procedures for financial institutions and payment service providers (“PSP”) in Cambodia ...

DFDL | April 2021

Pursuant to the Prakas on Launching the Use Rules and Procedures of Bakong System dated 26 June 2020 and the Prakas on Management of Payment Service Providers dated 14 June 2017, the National Bank of Cambodia (“NBC”) has determined transaction amounts and KYC procedures for financial institutions and payment service providers (“PSP”) in Cambodia ...

DFDL | February 2022

The General Department of Taxation (“GDT”) issued Instruction no. 1972 GDT on 31 January 2022 (“Instruction 1972”) which sets out obligations for taxpayers in Cambodia that carry out projects for public interest in connection with a grant or loan agreement (“Agreement”) or memorandum of understanding (“MoU”) between the Royal Government of Cambodia and another government or national development agency or partner international organisations ...

DFDL | June 2022

On the 25th of May 2022 the General Department of Taxation (“GDT”) issued Notification No. 10979 GDT on the “Required Documents to Support the Interest Charge on Related Party Loans” (“Notification 10979”). The key points to be taken from Notification 10979 are as follows: To ensure compliance with Prakas No. 986 MEF.P ...

DFDL | February 2021

On 12 January 2021, the Ministry of Economy and Finance issued Prakas N0. 009 on the Reclassification of Taxpayers under the Self-Assessment Taxpayer Regime (“Prakas 009”). The purpose of Prakas 009 is to amend the previous classification of taxpayers to ensure that the collection of taxes are carried out in a transparent and equitable manner which is in line with the growth of the Cambodian economy ...

DFDL | February 2022

January 2022 has seen the issuance of Instruction No. 002 AAR.N (“Instruction 002”) on the Compulsory Submission of Annual Financial Statements to the Accounting and Auditing Regulator (“ACAR”) and Instruction 001 AAR.I regarding the Submission to the ACAR on the use of English for computerized or other accounting systems (“Instruction 001”). We set out the salient points with respect to Instruction 002 and Instruction 001 below for your reference ...

DFDL | January 2023

This year marks the fifth anniversary of the introduction of the transfer pricing regime in Cambodia. Recent changes in local transfer pricing regulations, tax audit practices, and documentation mean that now – more than ever – you need the right advisor to reduce the tax audit risks associated with related party transactions. DFDL Cambodia’s specialized transfer pricing team combines international experience and deep knowledge of the local legal and tax environment ...

DFDL | May 2023

Overview The Law on Trusts promulgated on 2 January 2019 provides the legal framework for the creation, registration and inspection of trusts in Cambodia. To facilitate the implementation of the Trust Law, the Trust Regulator on 3 November 2022 issued Prakas 051 on the Formalities and Procedure for Inspection of Trusts (“Prakas 051”). Prakas 051 applies to the inspection of activities and operations related to the trust sector in Cambodia ...

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