Cambodia

Resident taxpayers include companies organised, managed, or having their principal place of business in Cambodia.

Permanent establishment (PE)

A non-resident company may be deemed to have a PE in Cambodia if (i) there is a permanent place or entity through which the non-resident persons carry on their business, (ii) there is an exercise of the authority to conclude a contract on behalf of a foreign entity, or (iii) business activities exceed certain time periods in Cambodia.

A person may be considered as a PE of a foreign entity if the person has and regularly exercises the authority to conclude contracts in Cambodia on behalf of a foreign enterprise or facilitate to have a contract signed.

Factors to be considered in determining a PE include a place of management, an agent or office, a warehouse or factory, a workshop, any place of extraction of natural resources, a plantation, etc. Carrying out projects (e.g. supervisory activities of a construction project, provision of services) exceeding a time period of six months in any 12-month period may also be considered as having a PE.