Tax laws Cambodia

Cambodia's tax system is overseen by the General Department of Taxation (GDT) and is designed to foster economic development and ensure tax compliance. Below are the key aspects of tax laws in Cambodia:

1. Corporate Income Tax (CIT)

Corporations in Cambodia are subject to corporate income tax on their profits.

  • Standard CIT Rate: The corporate income tax rate is 20% for most companies.
  • Small and Medium Enterprises (SMEs): A reduced rate of 15% is applied to small and medium-sized enterprises, depending on their level of income.
  • Exemptions: Certain industries, such as those in the agriculture sector, may be eligible for tax exemptions or preferential tax treatment.
  • Minimum Tax: Cambodia imposes a minimum tax of 1% of the annual revenue for most companies. However, if the company’s tax liability exceeds this amount, the regular CIT will apply.

2. Personal Income Tax (PIT)

Personal income tax is levied on individuals based on their earnings. The system is progressive, meaning higher incomes are taxed at higher rates.

  • PIT Rate: The personal income tax rates range from 0% to 20% based on income brackets. The tax brackets are:
    • Up to KHR 1,300,000 (approx. USD 325): 0% tax rate
    • KHR 1,300,001 to KHR 2,000,000: 5%
    • KHR 2,000,001 to KHR 8,500,000: 10%
    • KHR 8,500,001 to KHR 12,500,000: 15%
    • Above KHR 12,500,000: 20%

Employees earning a salary are subject to withholding tax by their employers, who are required to withhold taxes at the applicable rate.

3. Value Added Tax (VAT)

Cambodia operates a VAT system that applies to the sale of goods and services.

  • Standard VAT Rate: The standard VAT rate in Cambodia is 10%. This rate is applicable to most goods and services.
  • Exemptions: Certain goods and services are exempt from VAT, such as healthcare, education, financial services, and public transportation.
  • Registration: Businesses with an annual turnover of more than KHR 250 million (approximately USD 62,500) must register for VAT.

4. Withholding Taxes

Cambodia imposes withholding taxes on certain types of payments made to both residents and non-residents.

  • Dividends: Dividends paid to shareholders are subject to a 14% withholding tax for non-residents and 0% for residents.
  • Interest: Interest paid to non-residents is subject to 14% withholding tax.
  • Royalties: Royalties paid to non-residents are subject to a 14% withholding tax.
  • Payments to Foreign Service Providers: Fees paid to foreign service providers, including consultants, are subject to 15% withholding tax.

5. Capital Gains Tax

In Cambodia, capital gains from the sale of property or shares are taxed, but the specific rules depend on the type of asset.

  • Capital Gains Tax Rate: The capital gains tax rate is 20% for the sale of property or shares in most cases. This tax is applied to the net gain (selling price minus the purchase price).

6. Social Security Contributions

Employees and employers in Cambodia are required to make social security contributions for healthcare, pension, and other benefits.

  • Employee Contribution: Employees are required to contribute 3.75% of their salary to the social security fund, which covers health, pensions, and occupational risks.
  • Employer Contribution: Employers are required to contribute 4.75% for health and pension benefits.
  • Total Contribution: In total, social security contributions amount to 8.5% of an employee’s salary (with the employer covering most of the contribution).

7. Excise Taxes

Excise taxes are levied on specific goods, particularly luxury and harmful products.

  • Excise Duty on Goods: Commonly taxed goods include alcohol, tobacco, fuel, and automobiles. Rates vary depending on the product:
    • Alcohol: Rates are based on the volume of alcohol.
    • Tobacco: Tobacco products are subject to excise taxes.
    • Fuel: Petrol and diesel are subject to excise taxes, which are included in the price paid by consumers.

8. Property Tax

Property taxes in Cambodia are applied to land and real estate. The tax system for property is as follows:

  • Tax on Property: Property tax in Cambodia is based on the market value of the property.
    • For residential property, the tax rate is typically 0.1% of the property value per year.
    • For commercial properties, the rate is typically 0.1% to 0.2%.
  • Tax on Rental Income: Rental income is subject to tax. The rate varies, but it is generally 10% of rental income.

9. Customs Duties

Cambodia applies customs duties to goods imported into the country.

  • Customs Duty Rates: The rates vary depending on the type of goods. In general, rates range from 0% to 35%, with essential goods like food and medicine often receiving lower rates.
  • Free Trade Agreements: Cambodia is a member of ASEAN and benefits from various regional trade agreements that reduce or eliminate tariffs on certain goods.

10. Transfer Pricing

Cambodia follows international guidelines for transfer pricing to prevent tax avoidance through related-party transactions.

  • Transfer Pricing Regulations: Businesses involved in cross-border transactions must ensure that related-party transactions are conducted at market prices and are in compliance with Cambodia's transfer pricing laws. These rules are designed to ensure that companies pay fair taxes on their profits, regardless of where they operate.

11. Tax Incentives

To promote investment in certain sectors, Cambodia offers a range of tax incentives.

  • Investment Incentives: Certain investments, particularly in sectors such as manufacturing, agriculture, and high-tech industries, may qualify for tax exemptions, reductions in tax rates, or other incentives. These incentives are generally available for a fixed period and are subject to the type and scale of investment.
  • Special Economic Zones (SEZs): Investors in designated SEZs may enjoy various tax breaks, such as exemptions from import duties, VAT, and CIT for a period of time.

12. Double Taxation Treaties

Cambodia has entered into various double taxation treaties to avoid double taxation of income earned by residents in foreign countries.

  • DTAs: These treaties are designed to ensure that individuals and businesses are not taxed twice on the same income. The agreements typically provide for tax credits or exemptions for taxes paid abroad, and Cambodia has signed treaties with countries such as China, Thailand, and Vietnam.

Conclusion

Cambodia’s tax laws include a combination of income taxes, value-added tax (VAT), withholding taxes, excise duties, property taxes, and social security contributions. The tax system is designed to encourage investment, with certain tax exemptions and incentives for businesses in strategic sectors. Withholding taxes on dividends, interest, and royalties are significant for foreign investors, and Cambodia’s progressive personal income tax system ensures that individuals pay taxes according to their income level. The government also promotes economic development through various tax incentives and special economic zones.

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