Cambodia

Value-added tax (VAT)

VAT is applicable to self-declaration regime entities and is charged at 10% on the value of the supply of most goods and services.

Exported goods and services rendered outside Cambodia are zero-rated. In addition, 0% VAT applies to the supporting industries or contractors who directly supply goods (including milled rice) or services (including milled rice production services) to export-oriented garment, textile, footwear, bag, handbag, and headwear manufacturers, milled rice exporters, and domestic supplies of paddy rice.

Some supplies are VAT exempt, the main categories being public postal services, medical and dental services, electricity, water, transportation of passengers by wholly state-owned public transport systems, insurance services, primary financial services, and land. Some are exempt supplies under the Law on Financial Management 2017.

VAT returns and payments are due within 20 days of the following month. Note that strict record-keeping requirements do exist.

Import and export duties

Import duties are levied on a wide range of products. Rates vary from 0% to 35%. Following Cambodia’s entry into the Association of South-East Asia Nations (ASEAN) during 1999, the government is required to reduce import duties in accordance with the Common Effective Preferential Tariffs programme.

Export duties are levied on a limited number of items, such as timber and certain animal products (including most seafood).

Specific tax (SPT)

SPT is a form of excise tax that applies to the importation or domestic production and supply of certain goods and services. SPT on domestically produced goods is generally applied to the SPT base, which is 90% of the invoice price before VAT and SPT itself. For imported goods, SPT is due on the cost, insurance, and freight (CIF) value inclusive of customs duty. For hotel and telecommunication services, SPT is payable based on the invoice prices.

For local and international air transportation of passengers, SPT is 10%, payable based on the air ticket value issued in Cambodia for travel within and outside Cambodia. The SPT base is inclusive of all taxes other than SPT and VAT. For example, for return air tickets from Phnom Penh to Singapore costing 2 million Cambodian riel (KHR), exclusive of airport tax, the SPT payable is KHR 181,818 (KHR 2 million/1.1 x 10%).

Accommodation tax

Accommodation tax is calculated at 2% of the accommodation fee, inclusive of all taxes and other services except accommodation tax and VAT.

Tax for public lighting (TPL)

TPL is imposed on the distribution in Cambodia of both foreign made and locally produced alcoholic and tobacco products.

The TPL base for calculation of 5% shall be determined as follows:

• For producers and importers, the TPL base is the price recorded on the invoice inclusive of all taxes, except VAT and TPL itself.
• For further supply of the products to distributors/consumers, the TPL base is equal to 20% of the price recorded on the invoice inclusive of all taxes, except VAT and TPL itself.

Tax on immovable property (ToIP)

ToIP is levied at 0.1% per annum of the ToIP base. The tax base is 80% of the market value of the immovable properties stated in Appendix 1 of Prakas No. 371 less the threshold of KHR 100 million. The immovable property valued below the threshold is not subject to ToIP. The Prakas also determines that ToIP is effectively collected on immovable properties located in Phnom Penh and other cities of the provinces.

Immovable property is defined to include land, buildings, and other constructions on land (e.g. infrastructures built on land, regardless of having a wall or roof). Certain exemptions exist for government-owned property, agricultural land, property owned and used for cultural and religious purposes, property of foreign embassies and NGOs, and property in the special economic zones.

The owners, possessors, and final beneficiaries of immovable property are required to register and obtain a Tax Identification Number for each immovable property valued above the threshold from the tax administration where the immovable property is located. Any changes in relation to the registered immovable property (e.g. a change of title) are also required to be reported.

The owners, possessors, and final beneficiaries hold responsibility for calculating ToIP, preparing and filing a ToIP return, as well as remitting the ToIP liability to the tax administration once per year by 30 September. A ToIP return is required for every single immovable property and must be completed and filed separately. Since this is a self-assessment tax, the tax administration will perform a tax audit on ToIP in the subsequent years.

Tax on unused land

Land in towns and other specified areas without any construction, or with construction that is not in use, and even certain built-upon land, is subject to the tax on unused land. The tax is calculated at 2% of the market value of the land per square metre as determined by the Commission for Valuation of Unused Land on 30 June each year. The owner of the land is required to pay the tax on 30 September each year. The tax is paid by the owner on land that doesn’t fall under the scope of ToIP.

Stamp tax

Property

The transfer of title in certain assets (e.g. land, building, vehicles) and transfer of company shares (whether partial or full) are subject to stamp tax. The tax is imposed on the transfer values at the following rates:

• Transfer of assets: 4%.
• Transfer of shares: 0.1%.

The tax base for stamp tax on the soft and hard title transfer of immovable property (i.e. land) is the higher of:

• the property's value set by the appendix of the MEF's Prakas No. 962, or
• the property's value stated in a title transfer contract or other related legal documents if the transferred value is equal to or higher than the value set by the appendix of the Prakas.

Government contract

Stamp tax is imposed at the rate of 0.1% on the contract value of the public procurement contract for goods or services.

Document/signage

Stamp tax is to be paid on certain documents relating to the establishment, dissolution, or merger of a business, other official documents (perhaps more importantly for foreign investors), and certain advertising postings and signage. Amounts vary according to such factors as the type of documents, the location of the signage, illumination, and nationality of any scripted words. For certain documents, the tax amount is fixed up to KHR 1 million.

Cigarettes

Domestic producers or importers of cigarettes have the obligation to buy and affix tax stamps on packets of cigarettes. No person is allowed to sell or display packaged cigarettes for sale without a tax stamp.

Patent tax

Registered businesses must pay a (relatively nominal) patent tax on initial business registration and annually thereafter. Patent tax is levied with reference to turnover or estimated turnover.

The annual patent tax return and payment are to be filed annually, within three months of calendar year-end.

Tax on means of transportation

The tax on means of transportation imposes a number of statutory fees on the registration of certain vehicles, including trucks, buses, and ships.

Tax on Salary (ToS) and Tax on Fringe Benefits (ToFB)

Cambodia’s ToS rules follow internationally familiar residency and source principles. A Cambodian resident taxpayer’s worldwide salary will be subject to Cambodian ToS. For non-residents, only the Cambodian-sourced salary will be subject to ToS. The place of salary payment is not considered relevant in determining source.

A distinction is made between cash and fringe benefit salary components. Different tax scales also apply.

ToS or ToFB is a tax on employees’ income, but employers are held liable to these taxes if the employers fail to withhold.

The tax tables applicable to individuals (e.g. ToS, ToFB) are provided in the Taxes on personal income section of Cambodia’s Individual tax summary.

Social security contributions

Employers are currently required to make the Occupational Risks Contribution (ORC), payment for healthcare, and payment for pension to the National Social Security Fund (NSSF).

Payment for ORC

An employer with at least eight employees must register itself and all its employees with the NSSF.

The employer is required to contribute ORC equal to 0.8% of the monthly average wage of an employee to the NSSF’s designated bank account.

Payment for healthcare

In addition to the NSSF payment for ORC, the employer is also required to contribute, collect, and remit the contributions for healthcare and pension to the NSSF on a monthly basis. According to Sub-Decree No. 140, dated 26 August 2017, from 1 January 2018, the obligation to pay the contribution of healthcare is the full burden (100%) of the employer at 2.6% of the monthly average wage of employees. Previously, the healthcare contribution was required from both employers and employees, each equal to 1.3% of the monthly average wage of employees.

Payment for pension

Old-age pension (OP)

First stage: In the first five years, the pension contribution rate is 4% of the contributory wage of the worker/employee. The employer contributes 2%, while the other 2% comes from the worker/employee.

Second stage: In the next five years (i.e. the sixth to tenth years), the contribution rate is 8% of the contributory wage.

Third stage: The contribution rate will increase 2.75% in the 11th to 20th years, with subsequent increases of 2.75% every ten years.

Workers/employees who are NSSF members are entitled to receive an OP if they fulfil the following conditions:

1. Have registered for a pension scheme.
2. Are at least 60 years old.
3. Have paid contributions to the pension scheme for at least 12 months.

If condition 3 is not met, they will receive an old-age allowance instead.