Cambodia’s taxation rules vary according to the taxpayer’s regime, the classification of taxpayers under different tax collection and control procedures of the GDT. The self-declaration regime is the only tax regime in Cambodia. Under the self-declaration regime, taxpayers are classified into three categories (e.g. large, medium, and small taxpayers) based on their sectoral turnover, legal form, and other criteria (see table below).
|Type of taxpayer||Criteria|
|Small||Sole proprietorship or partnership:
If the declared turnover does not reflect actual turnover, the GDT will have the authority to re-determine the classification of a taxpayer based on the value of their assets used in the enterprise’s business.
Resident taxpayers are subject to tax on worldwide income while non-residents are taxed on Cambodian-sourced income only. A permanent establishment (PE) is taxable on its Cambodian-source income only.
Corporate tax rate
The standard rate of corporate income tax (CIT), previously known as tax on profit, for companies who are classified as medium and large taxpayers and PEs is 20%.
For companies who are classified as small taxpayers, the CIT rates are progressive rates from 0% to 20%.
Industry-specific tax rates
Oil and gas and certain mineral exploitation activities are subject to CIT at the rate of 30%.
Insurance companies are taxable at a rate of 5% on the gross premium income and at the rate of 20% on other income derived from non-insurance/reinsurance activities. Net interest income of insurance companies received after 4% or 6% WHT is not taxable income.
The small taxpayer is subject to CIT at the progressive rates as stated in Article 20 of the Law on Taxation.
Minimum tax (MT)
Self-declaration regime taxpayers are subject to a separate MT. The MT is an annual tax with a liability equal to 1% of annual turnover inclusive of all taxes except VAT.
As a separate tax to the CIT, the MT is due irrespective of the taxpayer's profit or loss position (i.e. the MT will be liable if the 1% of total annual turnover exceeds the 20% CIT liability).
According to the Law on Financial Management 2017, the MT is no longer applicable to enterprises that maintain proper accounting records from 1 January 2017. However, there is still no definition of what constitutes ‘maintaining proper accounting records’.
Local income taxes
Provincial and local income taxes are not applicable in Cambodia.