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Investing in Cambodia Seize the opportunity 2020 and beyond kpmg.com.kh
About KPMG
Who we are In Cambodia, our local experience,
enhanced by technical and
KPMG is one of the world’s leading industry knowledge of our global
professional services firms. We network, means we have the
are proud of our firm’s strong and tools and knowledge to gain a
established reputation, a reputation deep understanding of our clients’
that is built on a long history of businesses. It enables our professionals
independence, integrity and objectivity. to turn knowledge into value for the
It is what drives us to deliver clear and benefits of our clients, our people, and
practical advice to help our clients grow the capital markets.
and succeed in their chosen field.
Our leadership
It is what makes us committed and
successful leaders in our profession. KPMG in Cambodia commits to invest
in our people, services and quality to
Global presence help our clients achieve sustainable and
strong business performance.
KPMG is a global network of
professional services firms providing We are also committed to appropriately
Audit, Tax and Advisory services. delivering on our capital markets
responsibilities, as well as assisting our
We have outstanding professionals and clients in effectively communicating true
partners working together to deliver business performance to stakeholders.
value in over 147 countries worldwide.
KPMG's member firms aim to provide Supporting our communities
clients with a globally consistent set of KPMG in Cambodia has a long history
multidisciplinary financial and accounting of supporting the communities in which
services, based on deep industry we live and work. This contribution
knowledge. takes the form of our people’s time,
knowledge and experience, as well as
KPMG in Cambodia our financial donations and grants.
KPMG in Cambodia was established
in 1994. Today, with over 300
professionals, KPMG is one of the
largest professional services firms
in Cambodia with a balanced mix of
international and local clients.
Lim Chew Teng
Managing Partner
Cover photo credit: Dmitry A. Mottl Audit services
02 INVESTING IN CAMBODIA 2019
Table of contents
About KPMG Cambodia Setting up
economy business in
Cambodia
02 04 09
Accounting Other Cambodia
& reporting compliance Tax Guide
requirements requirements
10 11 12
Glossary
31
INVESTING IN CAMBODIA 2019 03
Cambodia economy overview
Cambodia is a member of Market Overview
Asociation of Southeast Economy
Asian Nations (ASEAN) Cambodia’s free-market economy with of the economy, the country still
and the World Trade its enviable GDP growth continues remains competitive in the region. In
to attract strong foreign investment, response to global trade concerns, the
Organization (WTO), and particularly from ASEAN and other government has introduced a draft of
enjoys Most Favored Asian countries. measures to reduce production and
supply costs and encourage further
Nation (MFN) status Cambodia has a strong labor
foreign investment.
protection regime, and while wages
and Generalized System are rising with the development
of Preferences (GSP)
program benefits and
Everything But Arms GDP, GDP Growth, Inflation
(EBA) program benefits 35 10
when trading with other 29 9
30
countries, especially the 25.9 8
24.3
25 22.2 7
United States (US) and
20 6
countries in the European 20
Union (EU). 5
15 4
3.2 3
Cambodia's GDP grew 10 3 2.8 3
by 6.7% in 2018 and is 6.9 7 6.7 6.6 2.2 2
6.3
5
projected to be 6.6% 1
for the year 2019. The 0 0
inflation rate was 2.8% in 2016 2017 2018 2019f 2020f
2018 and is projected to Nominal GDP Real GDP Growth Inflation
GDP by Sector (%)
10.6 9.7 10.9
Industry 9.6 9
6.8 7
5.6 5.9
Service 6.1
1.3 1.7 2 1.8
0.7
Agriculture
2016 2017 2018 2019e
2019f 2020f
Source: Economic Intelligence Unit
04 INVESTING IN CAMBODIA 2019
Banking System Land Ownership Business Sectors
Limited access to capital is one of The law restricts foreigners from Garment, light manufacturing,
the constraints of doing business in owning land in Cambodia. Foreigners automotive parts, luggage and
Cambodia. Commercial banks are are allowed to have a renewable long- furniture continue to be the country’s
primary sources of funding. term lease for up to 50 years plus key growth drivers, and attract new
50 years and freehold ownership of foreign investments each year.
From March 2018, the minimum
certain condominiums.
capital requirements for banking
institutions are as follows:
–– US$50 million for commercial
bank incorporated as foreign
branch, whose parent bank is rated Advantages of investing in Cambodia
"Investment Grade"
–– US$75 million for commercial bank
incorporated as foreign branch,
whose parent bank is NOT rated ASEAN membership offers regional trade
"Investment Grade"; a foreign benefits
subsidiary or a local company
–– US$15 million for specialized bank
incorporated locally
–– US$30 million for micro-finance WTO member since 2004 increasing trade
deposit taking institutions integrations
–– US$1.5 million for micro-finance
institutions.
Currency
The local currency, Khmer Riel Duty free or preferential export access to
(KHR), was introduced in 1980. The
most developed economies
Cambodian economy is classified
as partially dollarized, given that the
US dollar circulates in conjunction
with an official national currency,
as opposed to fully dollarized
economies where the dollar is the Favorable investment environment
only legal tender. 80% of deposits
and credits in the banking system
are made in United States Dollars
(US$)
One of Asia’s lowest labor costs and a
dynamic workforce
INVESTING IN CAMBODIA 2019 05
The Cambodia Securities Cambodia Securities Companies Listed on CSX
Exchange (CSX) is a joint Exchange (CSX) As of 31 August 2019, there are five
Companies listed on the CSX. Three
venture between the The Regulator State owned enterprise (SOEs) -
Cambodian Ministry of The Securities and Exchange Phnom Penh Water Supply Authority
Commission of Cambodia (SECC) (PWSA), Phnom Penh Autonomous
Economy and Finance, regulates the Cambodia Securities Port (PPAP), Sihanoukville,
which holds 55%, and the Exchange (CSX) in Cambodia. The Autonomous Port (PAS) and two
SECC is established under the law private companies - Grand Twins
Korea Exchange (KRX), on the Issuance and Trading of Non- International (Cambodia) Plc (GTI) and
which holds 45%. government Securities. Phnom Penh SEZ Plc (PPSP).
According to CSX link, there are two
(2) upcoming listing companies such
as Hattha Kaksekar Limited (HKL) and
PESTECH Cambodia Limited.
Corporate bond
As of 31 August 2019, 3 companies
issued corporate bond on the CSX
Nge Huy – Hattha Kasekor Limited (HKL),
Partner LOLC (Cambodia) Plc. (LOLC), and
Audit services Advanced Bank of Asia Limited (ABA).
Key Operating Rules
Market hours, trading times Minimum trading unit Daily price limit
Market is open from 8:00 am to 3:00 Price variance ranged from KHR10 to +/- 10% of the base price, or KHR10
pm, Monday-Friday and divided into KHR1000 dependent on share price. where the base price is below KHR100.
three sessions.
06 INVESTING IN CAMBODIA 2019
Settlement time
Settlement is performed two days after the trade, T+2,
at 8:30am
Account opening
Securities firms open accounts with a cash settlement
Key Settlement Rules agent and with the securities depository
Good faith deposit
A good faith deposit of 100% of the cash value of
the trade is required from the buyer and 100% of the
securities to be traded required from the seller
Clearing, settlement fees
Clearing fees are 0.05% of the value of the settled trade
Stock Trading on the Exchange Tax Incentives for Listing on CSX Currency of the Exchange
The SECC requires trades on the Listed entities that issue stock and/or To increase the use of the local
stock exchange to be settled after corporate bonds enjoy the following currency, all stock quotations on the
two days. benefits: CSX must be in Khmer Riel (KHR) only.
ACLEDA Bank Plc, Canadia Bank
–– 50% reduction of ToI for up to 3 SECC will help alleviate some of this
Plc, and the Bank for Investment
years from 4 January 2019 (date of risk at the outset by allowing dollar
and Development of Cambodia are
Sub-Decree on tax incentive). settlements by negotiation for the first
licensed as cash settlement agents
three (3) years.
by the SECC. –– Various tax debt waiver for
companies listing within 3 years
ACLEDA Bank Plc., Tricor Securities Securities Firms
from 4 January 2019 as follows:
Services Plc., and Phnom Penh
–– The SECC granted licenses to six
Securities Plc. are licensed as •• For N-3 to N-10 years for
underwriters and various market
securities registrar, transfer agent, enterprises who meet the
participants.
and paying agent by the SECC. criteria for listing in the primary
market.
•• For N-2 to N-10 years for small
and medium enterprises who
meet the criteria for listing in
the secondary market. Year N is
the year of IPO.
–– 50% reduction of withholding
tax on interest and/or dividend
derived from holding and/or buying
securities for three (3) years from 4
January 2019.
(Certain conditions are applied)
INVESTING IN CAMBODIA 2019 07
Key Requirements for listing on the CSX
A Listing Entity, which intends to transfer from Growth Board to Main Board, shall meet the listing criteria of its intended
transferring market and submit the application to the Cambodian Stock Exchange.
Main Board Growth Board
Shareholders'
KHR30 billion (US$7.5 million) KHR2 billion (US$500,000)
equity
–– KHR2 billion (US$500,000) for the –– Positive net income for latest year; or
latest year; and –– Positive operating cash flow & gross profit
Net Profit
–– Cumulative KHR3 billion (US$750,000) margin 10%
for the latest two (2) years
–– 200 shareholders; and –– 100 shareholders; and
–– 7% of the total voting shares Shareholder –– 10% of the total voting shares
Two (2) years Audited Financial One (1) year
Statements
Listing Eligibility
KHR4,000,000 (US$1,000) KHR2,000,000 (US$500)
Review Fee
–– 0.010% - 0.030% of total market
Listing Fee KHR4,000,000 or 0.025% of the
capitalisation
total market cap, whichever is larger
–– Minimum KHR10,000,000 (US$2,500)
–– 0.005% - 0.020% of total market KHR4,000,000 or 0.015% of the total market
capitalization Annual Listing Fee capitalization, whichever is larger
–– Minimum KHR3,000,000 (US$750)
–– Board members: At least 5 –– Board members: At least 3
–– Independent director: > 1/5 of total –– Independent director: >=1 or 1/5 if board
number of directors Corporate members >=5
governance
–– If foreign independent director: > 6 –– Non-executive director (as representative
months of working experiences in of the private shareholders) >= 1
Cambodia
a. Audit Committee a. Audit Committee
b. Nomination and Remuneration b. Risk Management Committee: Assets >
Committee KHR200 billion (US$50 million)
c. Board may consider to establish Risk BOD Committees c. Nomination Committee (optional)
Management Commitee and other d. Board may consider to establish it and
Committees as necessary and as other Committees as necessary and as
required by SECC required by SECC
08 INVESTING IN CAMBODIA 2019
Setting up business in Cambodia
Commonly used business entities 2. Branch
A new entity is registered with the For branch registration, relevant
Cambodian Ministry of Commerce documents and information of the parent
(MoC). Approval for registration usually company and the branch are required to
Many businesses require takes approximately ten (10) working be provided to the MoC. The Branch uses
days upon submission of all required the name of its principal e.g. "Branch of
documents. In general, businesses XYZ Co.Ltd.".
a license or permit to operate in Cambodia via the following
vehicles:
A Branch office can carry out trading
operate, including areas –– A company or subsidiary
activities such as sales and purchase of
goods and services.
such as banking and incorporated in Cambodia
–– A branch of a company incorporated
3. Representative Office (RO)
A RO is prohibited from undertaking
financial institutions, outside Cambodia
–– A representative office of a
profit making activities including buying
or selling of goods or services and
tour agencies, real company incorporated outside
Cambodia.
construction. A RO uses the name of its
principal e.g. "Representative Office of
estate agencies, Online business registration with
the MoC
XYZ Co.Ltd.".
Requirements for foreign investors
telecommunication The MoC uses an Online Business
Registration Service for registration and
For a foreign company, the full name,
address, nationality of the foreign investor
operators, industrial management of all commercial business
entities, including to keep their official
and the number of shares held in the
company are required to be disclosed to
factories, etc. information up to date, and complete
filings, without having to physically
the MoC.
For a Branch, the place of registration
attend the MoC. of the foreign company, details of its
structure and other information in the
Payment of registration fees can prescribed documents need to be
be made via the electronic banking disclosed to the MoC.
system. A payment receipt is issued by
an automated system as evidence of For a RO, the requirements are the same
payment. as for a Branch.
If the company or branch needs to
Main legal formalities for the new
apply for a particular license to carry
establishment and registration
out its business operations, additional
1. Company information from the foreign investor
The Law on Commercial Enterprise may have to be provided to the relevant
is silent on minimum capital government authority.
requirement. However, if the Currency/monetary restrictions
Memorandum and Articles of
Association fails to state number and Currently, Cambodia does not have any
price of the shares, the company must restrictions on funds transfer
(i.e. the repatriation of profits or capital
Michael Gordon issue a minimum of one thousand
(1,000) shares with a par value of
from Cambodia). Foreign currencies may
Senior Advisor not less than four thousand (4,000)
be freely purchased via the banking system
Tax and Corporate services and there are no ordinary restrictions on
KHR per share. Note that for certain
foreign exchange operations.
licensed activities, there are minimum
capital requirements. Generally, there
is no restriction on foreign ownership,
except for land holding. The name of
the company must first be cleared
with the MoC.
A memorandum and articles of
association has to be prepared for
the company and lodged with the
MoC, together with the prescribed
information for incorporation.
INVESTING IN CAMBODIA 2019 09
Accounting & reporting
requirements
Financial statements Law on Accounting & Auditing
The National Accounting Council (NAC) The Law on Accounting and Auditing sets forth certain accounting
of Cambodia has adopted International requirements which include, but limited to, the following:
Financial Reporting Standards (IFRS) for –– Enterprises and not-for-profit organizations are required to prepare
Small and Medium-sized Entities (SMEs) financial statements within three (3) months following the year-end.
and IFRS issued by the International
–– Financial statements form the basis for fulfilling tax obligations.
Accounting Standard Board (IASB)
effective for Financial Statements –– Accounting records must be maintained and the underlying transactions
with the period beginning on or after must be supported by proper documentation.
1 January 2010 and 1 January 2012, –– Accounting records and financial statements should be in Khmer
respectively. The standards are referred language and Khmer Riel, and a second set of accounting records
to as Cambodian International Financial and financial statements may be prepared in a foreign currency and
Reporting Standards for Small and in English language if the entity carries out its activities with foreign
Medium-sized Entities (CIFRS for SMEs) entities.
and Cambodian International Financial –– Enterprises and not-for-profit organizations are obligated to maintain
Reporting Standards (CIFRS). With the their accounting records for a period of ten (10) years.
exception of non-profit organizations,
public accountability entities and Book year
specialized banks are required to adopt Generally, the tax and accounting year is the calendar year. The tax and
CIFRS while non-public accountability accounting year end does not need to coincide with the calendar year,
entities that meet the audit requirements although any change must be approved.
below are required to adopt CIFRS
for SMEs or opt to use CIFRS, if Audit requirements
preferred. Non-profit organizations All enterprises that meet two of the three criteria set by Prakas No.
established in compliance with the 643 of the Ministry of Economy and Finance, must submit their annual
Law on Associations and NGOs are financial statements to be audited by an independent auditor (see the
required to prepare financial statements illustration below). The audit must be carried out by an auditor registered
and a report of operating activities but with the Kampuchea Institute of Certified Public Accountants and Auditors
are permitted to follow an accounting (KICPAA).
framework of their choice, following the
For Qualified Investment Projects (QIP) registered with the Council
issuance of Notification No. 30 from the
for the Development of Cambodia (CDC) in accordance with the Law
NAC to postpone the implementation
on Investment, there is an obligation to submit their annual financial
of the Cambodian Financial Reporting
statements to be audited by an independent auditor registered with
Standards for Not-For-Profit Entities
KICPAA.
(CFRS for NFPEs) on 21 January 2019.
Nevertheless, an updated Accounting
Framework to govern such entities is
expected to be released by the NAC in the
near future. Annual turnover above KHR3,000,000,000
(approximately US$750,000)
From 1 January 2019, Financial Total assets above KHR2,000,000,000
Institutions and General Insurance (approximately US$500,000)
Companies are also required to More than 100 employees
adopt CIFRS (for Banks, deposit
taking Microfinance Institutions, and
General Insurance Companies) and Audit requirements
CIFRS for SME (for non-deposit taking
Microfinance Institutions and Leasing
Companies) following the end of a
transition period previously granted to
these entities by the NAC.
10 INVESTING IN CAMBODIA 2019Other compliance
requirements
National Social
Security Fund (NSSF)
All entities with at least one (1)
employee are required to registered
with the NSSF, file monthly reports,
and make monthly contributions to
the NSSF for two social security
schemes: the "occupational
risk scheme" and "healthcare
scheme". The payment of monthly
contributions to the NSSF must
be performed by the 15th of the
following month and the employee
report must be reported to the
NSSF by the 20th of the following
month.
Certificate of Annual Declaration of
Compliance (CoC) Commercial Enterprise
Annually, all QIPs are required to (ADCE)
obtain a CoC from the CDC in order All entities registered with the MoC
to receive the investment incentives are required to prepare and file the
granted under the investment ADCE with the MoC once a year.
license. The CoC is intended to The filing must be done within three
provide confirmation that the QIP (3) months from the due date as
has complied with relevant tax and notified by an email from the MoC.
investment regulations.
Labor law compliance
Enterprises with at least one employee are required to register with the Ministry of Labor and Vocational Training
(MLVT). After the initial registration, enterprises are required to notify the labor office on an ongoing basis of any
relevant changes, such as staff movements. Enterprises wishing to employ foreign workers must apply for a foreign
manpower quota annually, and for work permits for foreign staff.
Other obligations for employers may include registration of internal work rules and fulfilling trade union and staff
representative election requirements.
INVESTING IN CAMBODIA 2019 11Cambodia Tax Guide The principal taxation law of Cambodia is the Law on Taxation (LoT)
adopted by the National Assembly in January 1997. In 2000, the Ministry
of Economy and Finance issued a Prakas (regulation) on Tax on Profit
(currently called “Tax on Income”) to clarify certain tax provisions
Taxpayers wil be stipulated in the 1997 Law. The Law on Amendment on the LoT (LALoT)
was signed into Law in March 2003, and the revised Prakas on Tax on Profit
required to submit and was issued in December 2003. Subsequently, certain Laws on Financial
Management have included amendments and updates to the existing Law.
pay taxes to the General Overview
Department of Taxation Subsequent to the promulgation of the 2016, 2017, 2018, and 2019 Law
on Financial Management (LoFM), the tax regime system received major
(GDT) on an annual and restructuring.
monthly basis. Currently, there is only one tax regime, the Self-Assessment Regime (SAR)*,
which is further divided into three classes of taxpayers:
Classes Turnover criteria Accounting standard
Mona Tan Small taxpayer** From KHR250 million Simplified accounting
Partner (~US$62,500) to KHR700 standard
million*** (~US$175,000) per
Tax and Corporate services
annum, or more than KHR60
million (~US$15,000) for three
consecutive months within the
current calendar year
Medium taxpayer From KHR700 million International accounting
(~US$175,000) to KHR4,000 standard of Cambodia
million (~US$1,000,000) per
Large taxpayer More than KHR4,000 million International accounting
(~US$1,000,000) per annum standard of Cambodia
The classification is also dependent upon the form of the enterprise as well as
the business activity.
Medium and large taxpayers will be required to submit and pay taxes to the
General Department of Taxation (GDT) on an annual and monthly basis. This
mainly involves the following taxes:
–– Annual Tax on Income or Minimum Tax (see 1)
–– Annual Patent Tax (see 3)
–– Monthly Prepayment of Tax on Income (see 1)
–– Monthly Tax on Salary and Fringe Benefit (see 2)
–– Monthly Value Added Tax (see 3)
–– Monthly Withholding Tax (see 3)
* Previously it was called “Real Regime Tax System”, and then changed to SAR under the 2017 LoFM
** Small taxpayer is required to submit a monthly tax return in one single form, called form “TRS 01”
*** New turnover threshold as per Prakas no. 025, amendment of taxpayer classification, dated 24 January 2018.
12 INVESTING IN CAMBODIA 201901 Taxation of companies
Introduction Residence Exempt Income
A company is resident in Cambodia if: Dividends received from resident
Corporate taxpayers in companies are not subject to
–– It is organized or managed in
Cambodia are classified as Cambodia; or income tax.
either resident taxpayers, or –– It has its principal place of business Deductions
non-resident taxpayers. in Cambodia.
Allowable Deductions
A resident taxpayer is Taxable Income Allowable deductions include most
primarily an enterprise that Taxable income is the net income expenses incurred in the course of
has a place of management realised from all results of business carrying on a business, with certain
and carries on business in activities and other non-business limitations. The deductibility of
activities of the physical person or charitable contributions is limited
Cambodia, as defined below. to 5% of taxable income of the
legal person.
A non-resident taxpayer is taxpayer.
Taxable income includes capital gains,
an enterprise that derives Depreciation is allowed as a deduction
interest, rent, royalty, and income
Cambodian source income, from financial assets or investment in accordance with the rates
but does not have a place of assets including immovable property. determined by the tax provisions.
management in Cambodia. There are also certain restrictions on
For legal persons, the taxable income the deductibility of interest.
shall be the result from adjustment
A non-resident taxpayer will of accounting results in the tax year Non-deductible Expenses
be deemed to be Cambodian in accordance with the provision on Non-deductible expenses include:
resident for tax purposes taxation.
–– Increase in provisions
if it is found to have a For physical persons, taxable income –– Any expense on activities generally
Permanent Establishment is the result from total income in the considered to be amusement,
(PE) in Cambodia (see 6 for tax year offset by expenditures and recreation, entertainment
other allowance (to be determined by
PE definition). a Sub-Decree). –– Personal expenses, except for
fringe benefits which are subject
A resident taxpayer is Rules and procedures for taxation to fringe benefit tax
subject to Tax on Income are further determined by Prakas –– Any loss on sale or exchange of
(ToI) or Corporate Income (regulation) by the Minister of property, directly or indirectly,
Economy and Finance. between related parties
Tax (CIT) on income derived
from both Cambodian and Capital Gains Tax –– Penalties, additional tax and late
payment interest imposed for
foreign sources, whereas, All realized gains (including capital violation of the LoT
a non-resident taxpayer is gains) are treated as income.
–– Non-deductible tax expenses
Cambodia does not impose a separate
subject to ToI/CIT in respect –– Donations, grants or subsidies and
tax on capital gains. Gains arising
of its Cambodian source from the disposal of real estate –– Extravagant and / or unrelated
income only. property and other assets are treated business expenses.
as ordinary income and are therefore
subject to tax at the prevailing ToI rate. Losses
Dividends Tax losses can be carried forward for
a maximum of five (5) years (except
A dividend is defined as a distribution for tax loss of petroleum and mineral
of property or money, made by a resource operation as discussed in
legal person to a shareholder with the page). Losses cannot be carried
the exception of distribution of capital back. Tax losses may be forfeited
or equity interest in a complete upon a change in ownership of the
liquidation of the Company. business or if there is a change in
Dividends received from non-resident business activity.
companies are subject to income tax Tax losses will also be forfeited in
in Cambodia. A credit is allowed for the event a taxpayer is subject to a
tax paid overseas on foreign source unilateral tax assessment.
income, subject to certain conditions.
INVESTING IN CAMBODIA 2019 13Grouping/Consolidation Unutilized charitable contribution –– 0% on income of the QIP during
expense cannot be carried forward as the tax exemption period as
There are no grouping or consolidation
a deduction against taxable income in determined by CDC.
provisions in Cambodia.
future year. –– For insurance enterprises, ToI
Tax Depreciation/Capital shall be:
Interest Expense
Allowances –– 5% of gross premium
The allowable interest deduction on
Depreciation is deductible in received for general insurance,
loan shall be allowed as follows:
accordance with specified rates if reinsurance or small scale
1. For loans from non-related party, enterprises, which includes
the assets are used in the course of the interest expense shall not
carrying on a business. property, liability and health
exceed 120% of the market insurance.
Land is not a depreciable asset. interest rate, and
2. For loans from related party, the –– Subject to normal CIT/ToI rate
Depreciable assets are divided
interest expense shall not exceed of 20% for life insurance or
into the following classes, and are
the market interest rate. reinsurance enterprises, which
depreciated at the following rates:
includes life, endowment and
The GDT will issue the market
Class 1: Buildings and structures – annuity insurance.
interest rate annually.
5% straight line
Interest rate between related parties Foreign company branches are
Class 2: Computers, electronic must also be in accordance with the generally subject to ToI on the same
information systems, arm’s length principle following rules basis as a company as noted above,
software and data and regulations provided per Prakas for instance remittance of profit to
handling equipment – 50% 986 (Please refer to section 6 below) the overseas Head Office will be
diminishing value and there are documentations that subject to the Additional Income Tax
taxpayers are required to maintain on Dividend Distribution (AITDD)
Class 3: Automobiles, trucks, office
to support loans between related unless the profit has been subject
furniture and equipment –
parties; to and fully paid ToI. Furthermore,
25% diminishing value
if the branch is making transfer of
–– Loan agreement with clear terms
Class 4: All other tangible property – of borrowing; Cambodian sourced income to its
20% diminishing value overseas parent company it is also
–– Business plan in relation to the loan; required to withhold the 14% WHT.
Fixed assets in class 2 to 4 are
accounted for on a pooled basis, –– Documents to explain the basis of
the interest rate; and Tax on Petroleum and Mineral
and therefore capital gains or losses Resources Operations
on the disposal of fixed assets are –– Board of Director’s resolution.
not calculated individually but are With the 2018 LoFM, promulgated
The interest expense as per points
calculated based on the result of the on 9 December 2017, there was
1&2 above are still subject to below
an amendment on the existing tax
pooled asset account. limitation of the interest deduction.
law by adding additional Articles
Additions for fixed assets from class 1 Interest expense allowable as a on the tax provisions on petroleum
to 4 are depreciated for the full year in deduction is limited to an amount and mineral resources. As per the
the year of acquisition. equal to the total interest income 2018 LoFM, taxpayers conducting
plus 50% of net non-interest income Petroleum and Mineral Resources
Amortization of Expenditure earned for the year. Net non interest operations shall be subject to:
profit is the gross income, other
Intangible assets, including preliminary than interest income, less allowable * Annual ToI rate of 30% on taxable
and formation expenses, R&D, non-interest expenses. The excess income during a tax year;
patents, copyrights, trademarks, amount can be carried forward to
computer software, and purchased * Tax on Excess Profit at a
future years.
goodwill can be amortized over the progressive tax rate by tranche based
useful life of the property. If the life The petroleum and mineral resources
sectors are subject to a specific tax
of the intangible assets cannot be
regime for interest expense. Tranche Excess profit ratio Rate
determined, a tax depreciation rate
of 10% based on the straight-line Tax Rates
method is used. 1 up to 1.3 0%
The Cambodian Tax Law provides the
The petroleum and mineral following corporate income tax or 2 above 1.3 to 1.6 10%
resources sectors are subject to a annual ToI rates:
specific tax regime for expensing of 3 above 1.6 to 2 20%
–– 20% on income realized by a
exploration and development costs.
legal person.
Charitable contribution –– 30% on income realized under 4 above 2 30%
an oil or natural gas production
The deductibility of charitable sharing contract and the
contribution expense is limited to exploitation of natural resources
5% of the taxable income after tax including timber, ore, gold and
adjustments and before deduction of precious stones.
charitable contribution itself.
14 INVESTING IN CAMBODIA 2019* Loss carried forward is allowed until Payment of Tax
the tenth year for petroleum operations A company is subject to a monthly
and the fifth year for mineral resource prepayment of ToI (PToI) during the
operations;
year, which is self-assessed at 1%
* Deduction for interest expense is on monthly turnover inclusive of all
subject to debt to equity ratio of 3:1 rule; taxes except for Value Added Tax
* There are various other tax (VAT).
treatments, for example, depreciation, Insurance companies are required to
deductions, transfer of interest, etc. declare and pay the monthly PToI at
that is applied for this sector as recently the rate of 5% on gross premiums
provided under the 2018 LoFM. from insurance or re-insurance
Sales agents supplying goods on income and at the rate of 1% on
behalf of principals other related income as indicated in
Recognised agents (i.e. travel agents, Tax Rate Section above.
sales depots), supplying goods or Payments of PToI are due by the
services on behalf of principals, are 20th day of the following month.
not required to declare and pay taxes The liquidation of the ToI is the
on the sales on behalf. They are only balance of tax payable after deduction
obligated to collect those taxes on of all tax credits and PToI and must
behalf of the principals and pay PToI be paid upon submitting the annual
and ToI on commissions earned from ToI return to the GDT which must
the principals. be done by 31st March in the year
To get recognition as sale agents, following the tax year1.
enterprises must fulfill certain The minimum tax2 is a separate
conditions such as being a medium and distinct tax from the ToI, and is
or large taxpayers, having contracts payable by companies regardless
with the principals, no change of of whether they are in a profit or
ownership of the goods, maintain loss situation. The minimum tax is
invoices compliance, and keeping calculated at 1% on annual turnover
inventory of the goods. A sales inclusive of all taxes except for VAT.
agent can apply and receive agent However, if the ToI is greater than
certificate from the GDT which is the minimum tax, the minimum tax
valid for 2 years. Without proper is not payable. The minimum tax is
recognition and certificate, the sales calculated at year-end, however it
agents would be liable to all kinds of should be totally liquidated by the
taxes relating to sales on behalf as if monthly PToI.
these sales were their own income.
Tax Credits
Tax Administration Tax paid overseas on foreign source
Tax Identification Number income is available as a tax credit,
Business entities are required to subject to the taxpayer providing
register with the tax administration sufficient evidence to substantiate
within fifteen (15) working days, from the foreign tax paid. The tax credit is
the commencement of economic calculated separately for each foreign
activities, or after receiving the country and is the lower of the
registration approval certificate or foreign tax paid and Cambodian tax
approval letter from the relevant payable on foreign source income.
ministries or institutions. Record Keeping
Tax Returns All books of accounts, accounting
The annual tax return must be filed records and other documents must
within 3 months following the tax be maintained in the Khmer language
year. The tax year is generally a and in KHR, and kept for a period of
calendar year. The return must be ten (10) years.
filed irrespective of whether the
company is making a profit or loss.
1: Tax year is calendar year, but an enterprise can apply for a tax year other than calendar year, for example,
to be consistent with its parent company/ if the foreign parent company owns more than 51% equity
shares.
2: The minimum tax shall be imposed on taxpayer who maintain "improper" accounting records (i.e. effective
from the tax year 2017 onwards). Under the LoFM 2018, petroleum and mineral resource operations are
not subject to minimum tax.
3: Suspensions: 1% PToI is suspended for enterprises in the agricultural sector such as: planting, producing
and supplying certain agricultural products for 5 years starting from January 2019 and the garment industry
until the end of 2022.
INVESTING IN CAMBODIA 2019 15
15$ $
LandArea Population Capital City Trade
Trade Balance
Balance Minimum
Approximately Phnom Penh Imports US$17.5
Imports US$18.8 Wage
181,035km 2 16.2
(2018)
million Provinces & Cities billion
billion (2018)
(2018)
Exports US$12.8
Exports US$12.7 US$182/month
16.7
(2020(f))
million 25 billion
billion (2018)
(2018) (2019f)
$ $
$ $
GDP Growth % GDP
GDP GDP/ capita Exchange rate Inflation
US$ 24.3
24.3 billion
6.7%(2018) US$ billion US$1,384
US$4,002 US$ to KHR
2.8%
6.3% (2020f) US$
(2018)
(2018e)
29 billion
US$ 29.0 billion
(2017)
(2017)
4,054
4,084(2018 avg.)
(2018)
(2020f)
(2020f)
100 + 0.0% 0.0%
95 - 99 0.0% 0.0%
90 - 94 0.0% 0.0%
85 - 89 0.1% 0.1%
80 - 84 Male 0.2% 0.2% Female
75 -79 0.3% 0.5%
70 - 74 0.5% 0.7%
65 - 69 0.8% 1.2%
60 - 64 1.0% 1.6%
55 - 59 1.6% 2.0%
50 - 54 2.1% 2.4%
45 - 49 2.4% 2.7%
40 - 44 1.7% 2.0%
35 -39 3.9% 4.2%
30 -34 4.3% 4.6%
25 -29 4.5% 4.4%
20 - 24 5.0% 4.8%
15 - 19 4.6% 4.5%
10 - 14 4.9% 4.7%
5 -10 5.5% 5.2%
0-4 5.6% 5.4%
-8.0% -6.0% -4.0% -2.0% 0.0% 2.0% 4.0% 6.0% 8.0%
Population of Cambodia 2018 Source: PopulationPyramid.net
16 INVESTING IN CAMBODIA 201902 Taxation of individuals Deductions
Employees are not allowed any
deductions against their salary
income as employees are not
Introduction Exempt Income
required to submit annual tax returns.
Employment related payments
Individual residents of received by a tax resident that are Tax Administration
Cambodia are liable for personal not subject to income tax include: Returns and Assessments
income tax/tax on salary (ToS)
–– Reimbursement of business The salary and fringe benefit tax
on Cambodian and foreign expenses by the employer, return and payment are due to be
source income, whereas non- provided that the costs are incurred filed and paid to the GDT by the 20th
residents are subject to income in the course of employment, the day of the following month. Currently,
tax on Cambodian source amounts are not excessive and the Cambodian Tax Law does not
income only. A credit for foreign they can be substantiated; require a resident individual to submit
income tax paid is allowed against –– Indemnity for layoff within the limit an annual personal income tax return
Cambodian income tax. as stated in the Labor Law; to the GDT. Accordingly, the monthly
salary tax deduction is considered to
The tax credit is calculated –– Additional remuneration received be a final tax for individuals.
separately for each foreign with social characteristics as
provided in the Labor Law; Personal Allowances and Rebates
country and is the lower of the of Tax
foreign tax paid and Cambodian –– Supply of free or subsidized
tax payable on foreign source uniforms or special professional The following relief is provided to a
equipment used in the course of resident employee:
income.
employment; and
Employers are required to –– Flat allowances for mission and Relief for the month KHR
withhold income tax from travel received in the course of Child relief for each
salaries and other benefits paid employment. child (14 years old or
to employees. Salary is taxed * Employees under "Undermined 25 years old if still at 150,000
according to progressive tax Duration Contract" (UDC) are entitled school)
rates ranging from 5% to 20%. to annual seniority payments,
including existing employees before Dependent spouse
Resident/Non-Resident 2019 and newer employees. ToS shall (must be housewife) 150,000
A person is a resident of Cambodia be exempted the seniority payment
if the person is “domiciled in” or for Khmer employees. Tax Rates
has a “principal place of abode” in The following allowances may be Residents
Cambodia, or the person is present exempted from either ToS or FBT: The ToS rates are as follows:
in Cambodia for more than 182 days
during any 12 month period. –– Commuting expenses (between
Taxable Income
home & workplace), accommodation Progressive
A non-resident means any person allowances, and accommodation for the Month
Tax
who does not fall under either of the provided within the Company’s (KHR)
above stated criteria. premise (all in accordance with Labor
Up to 1,200,000 0%
Law),
Employment Income/Employee From 1,200,001 -
–– Meal allowances where provided to 5%
Individuals receiving remuneration in all worker-employees regardless of 2,000,000
the course of employment are subject position/function, From 2,000,001 -
to personal income tax known as 10%
–– Social security or welfare fund 8,500,000
tax on salary. Remuneration includes (within the limit of the law),
salary, wage, bonus, overtime and From 8,500,001 -
15%
other compensation. A fringe benefit –– Health insurance or life/health 12,500,000
tax on employer-provided cars, insurance premium where provided
to every employee regardless of Over 12,500,000 20%
housing, low interest loans, and
free, subsidized or discounted goods position or function, Non-residents
and services is levied on employers –– Baby care allowance or baby nursery Non-residents are taxed on salary from
according to the taxable value of expense (in accordance with Labour Cambodian sources at a flat rate of 20%.
the fringe benefits provided to their Law)
employees. The tax rate is currently Companies and enterprises are required 1. As noted in section 1 above, individual person
20% and it is payable monthly. The to submit an allowance policy for the
taxable income (allowable deductions) will be
determined by a Sub-Decree which has not been
actual cost of providing the benefit will above allowances to the GDT to be issued as of the date of this update. Currently,
normally be deductible for the employer eligible to the above tax reliefs. individual is not required to file their annual
except for the fringe benefit tax. personal income return to the GDT.
INVESTING IN CAMBODIA 2019 1703 Indirect and other taxes
Value Added Tax (VAT) Enterprises providing taxable supplies of goods and
services are required to register for VAT if they meet the
VAT is chargeable on a wide range of goods and services
criteria below:
supplied in Cambodia and on the importation of goods.
The basic principle of VAT is to charge tax at each stage of –– Corporations, importers, exporters and investment
production, allowing each supplier credit for the tax paid, companies;
so that the VAT eventually impacts the final consumer.
–– Taxpayers with turnover in respect of goods sold
Taxable supplies attract VAT at either the standard rate exceeding KHR125 million for the preceding three
of 10% or the zero rate. The zero rate applies to export consecutive months or in the next three consecutive
of goods and services and certain charges in relation to months;
international transport of people and goods. Also, this
–– Taxpayers with turnover in respect of services provided
zero rate is applicable for any goods and services supplied
exceeding KHR60 million for the preceding three
by supporting industries QIP/contractors to particular
consecutive months or in the next three consecutive
export industries. For supply of services to use zero
months; and
rate, the services must have been performed outside
Cambodia or performed for uses outside Cambodia –– Taxpayers that have contracts with government with a
and the services are not for the business purpose or total taxable turnover exceeding of KHR30 million.
economic interest inside Cambodia (the burden of proof
VAT registration must be made at the commencement
is on the taxpayers). Documents such as contracts, bank
of business operation or within 30 days in which the
statements, invoices, etc., must also be maintained for
taxpayer becomes a taxable person.
the tax administration’s review.
VAT returns and payment are due to be filed and paid to
VAT on certain supply and import of certain agricultural
the GDT by the 20th day of the following month.
products shall be borne by the State (i.e. State Charges).
VAT is payable at 10% on the value of imported goods,
Exempt supplies are not subject to VAT and include:
including any customs duty, insurance and freight charges.
–– Public postal service;
The GDT set up an online VAT management system to
–– Hospital, clinic, medical, and dental services and manage taxpayers’ VAT refund requests and VAT credit
sales of medical and dental goods incidental to the utilisation. GDT issued Notification and Instruction in
performance of such services; January 2019 for implementation without any specific
implementation dates*. With the system, the taxpayers
–– Passenger transportation services by a wholly state-
can access the system to record VAT input and output then
owned public transportation system;
print out a report for either a VAT refund request or a VAT
–– Insurance services; credit claim to be attached with monthly VAT return.
–– Primary financial services; * The system and the requirement to print out VAT credit
report was meant to be implemented in January 2019.
–– Importation of articles for personal use that are exempt
However because of the system errors due to high volume
from customs duties;
of usages and many taxpayers could not access the
–– Non-profit activities for public interest that have been system, the requirement to print out and attach the VAT
recognized by the Ministry of Economy and Finance; report was postponed twice.
–– Educational services;
–– Supply of unprocessed agricultural products;
–– Supply of electricity; and
–– Supply of water for public use; and solid-liquid trash
collection or cleaning service
18 INVESTING IN CAMBODIA 2019Specific Tax on Certain Merchandises and Services Accommodation Tax (AT)
(STCMS)
AT is a tax on the provision of accommodation services.
Certain goods and services are subject to STCMS, which is AT is levied at the rate of 2% on accommodation services
a form of excise tax that applies to importation or domestic fees, inclusive of other services charges and all kinds of
production and supply of certain goods and services. taxes but exclusive of the AT itself and VAT. Payment of AT
to the GDT is due on the 20th day of the month following
Examples of the levy of STCMS are:
the month in which the charges occur.
Item Rate Other Taxes
Domestic and international Withholding Taxes (WHT)
telephone services 3%
Resident with holding tax
Domestic and international A resident taxpayer is required to withhold tax from the
air ticket 10% following payments of Cambodian source income to a
resident entity:
Entertainment services
Payment Rate
10%
Payment for services to a
Cigarettes physical person, including 15%
20% management, consulting, and
other similar services1
Beers Payment of royalties for
30% intangible assets and interests 15%
in minerals, oil or natural gas
Wine
Interest payments made
35% 15%
to a physical person or an
enterprise, except for interest
paid to a domestic bank or
savings institution
For domestically produced goods, the basis for STCMS’s Income from rental of
calculation is 90% of the selling price disclosed on the movable or immovable 10%
invoice exclusive of VAT and STCMS. properties
Payment of STCMS to the GDT is due on the 20th day of
Interest payments on a fixed
the following month. 6%
deposit made by a domestic
Tax for Public Lighting (TPL) bank or savings institution to a
resident taxpayer
TPL is a tax levied on the sales of alcohol and cigarette
products, both imported and domestically manufactured,
at each stage of supply. Interest payments on savings
The basis for TPL calculation* is as follows: account made by a domestic 4%
bank or savings institution to a
- For importer or manufacturer, the tax rate is 3% of the resident taxpayer
value of taxable product exclusive of VAT and TPL itself.
- For reseller and/or distributor, the tax rate is also 3%,
but the basis is now only 20% of the amount recorded on
invoice, exclusive of VAT and TPL itself.
The tax is payable on a monthly basis, by the 20th day of
the following month.
* the revised calculation for reseller and/or distributor was effective 9
October 2017 onward,
1: The 15% WHT on service is not applicable if the recipient of the payment is a real - regime tax payer, provided that a valid invoice is obtained.
INVESTING IN CAMBODIA 2019 19Non-Resident WHT Conversion of retained earnings to capital/equity will not
Any resident taxpayer carrying on business, including be considered as dividend distribution and is not subject
PE of non-resident taxpayer, who makes payment from to WHT (supported by BoD resolution).
Cambodian source income to a non-resident, shall If there is transfer of shares in capital or equity interest
withhold and pay as tax an amount equal to 14% of the (partly or wholly) of a company which has retained
amount payable. Payment from Cambodian source income earnings related to the share transfer whether or not has
may include the following: been converted to share capital distribution of dividends,
and will be subject to 14% WHT.
Payment Rate
In case there is a reduction of capital or equity interest,
Interest 2
the reduced amount shall be considered distribution of
14%
dividends, and will be subject to 14% WHT. However, the
Income from movable or immovable deemed dividend shall not exceed the amount of retained
property, if such property is situated 14% earnings.
in the Kingdom of Cambodia.
Under existing Double Tax Agreements (DTA) in effect, the
Management or technical services 14% WHT on certain payments such as interest, royalties,
14% technical service fees & dividends to resident of the DTAs
signatories is reduced to 10% WHT (provided Cambodian
resident taxpayers complied with certain requirements of
Dividends the GDT on a case by case basis). Please refer to section
14% 5 below for DTAs signatory countries.
The small taxpayers are exempted from the obligation to
act as withholding agents, except with regard to the WHT
on rental fees for movable and immovable properties.
Other various Cambodian source
income(s) as provided in the 14% Note: The liability for WHT rests with the remitter. The
Article 33 (new) of 2003 Law GDT has no recourse to recover withholding tax from the
on Amendment on the Law on recipient of the payment. The WHT is payable at either
Investment (LALoT) the date the payment is made, or the date the expense is
recorded in the books, whichever is first.
Payment of WHT to the GDT is due on the 20th day of the
following month.
2: For MFI, making interest payment to non-resident will only be subject to a reduced rate of 10%.
(4% will become state-charge for 2017 and 2018, effective from 27 October 2017).
20 INVESTING IN CAMBODIA 2019Additional Income Tax on Dividend Distribution Patent Tax
(AITDD) Patent tax is a yearly business registration tax which all
AITDD is imposed on any dividend distribution, by enterprises carrying on business activities in Cambodia
calculating the difference between Tax on Income payable are required to pay by 31st March. A “patent tax
and Tax on Income paid during the year. certificate” will be issued by the GDT upon registration
and/or after each successive change or update with the
If the dividend distributed has already deducted AITDD or
GDT of information of the enterprise that affects the
ToI, then the recipient company can record in a dividend
patent tax certificate.
account. Subsequent distribution of the said dividend
to the recipient enterprise’s shareholder shall then be If the enterprise carries out different types of businesses,
exempted from AITDD. Payment of AITDD to the GDT is a separate patent tax certificate is required for each
due on the 20th day of the following month in which the distinct business activity. Likewise, if a taxpayer carries
distribution is paid. out business in different cities or provinces, a separate
patent tax certificate is required for each location.
The amount of patent tax payable will be depending upon
the form of the business, as well as the type of business
activity and the level of turnover.
Patent Tax
Large Taxpayers*: either Medium Taxpayers: Small Taxpayers:
KHR3,000,000 (~US$750),if annual KHR1,200,000 (~US$300) KHR400,000 (~US$100)
turnover is between KHR4,000
million and KHR10,000 million; or
KHR5,000,000 (~US$1,250) if annual
turnover is over KHR10,000 million
* Large Taxpayers are required to pay KHR3,000,000 (~USD750) for each additional patent tax certificate,
if the enterprise has any branch, warehouse or business in different cities or provinces.
INVESTING IN CAMBODIA 2019 21Customs Duty Desk audit is focused on clear and easy to find irregularities
on the tax returns through reconciliation with available
Customs duty is levied on certain goods entering
information and interviewing taxpayers. This can be
Cambodia. The rates vary depending on the type of goods.
conducted within 12 months after tax return lodgement.
Currently, the duty rates are 0%, 7%, 15%, and 35%.
Limited audit is limited in length and is focused on most
As a member of ASEAN, Cambodia has also implemented the
taxes except ToI. This can be conducted on current tax year
ASEAN Trade in Goods Agreement (ATIGA) which entered into
(N) and one prior tax year (N-1).
force on 17 May 2010. In accordance with ATIGA, the customs
import duties was reduced to 0-5 percent on most goods. Comprehensive audit is conducted on all kinds of taxes
and information necessary. This can be conducted within
Exemptions can also be obtained as part of the incentives
3 tax years backwards (N-3). This can be extended to 5 tax
offered by the CDC for the QIP undertaken in Cambodia.
years backwards (N-5) if there is evidence of tax evasion
Registration Tax or there are losses or credit carried forward from longer
than 3 tax years backwards. The tax year that is subject to
Registration tax of 0.1 % applies to a transfer of shares. comprehensive audit and any outstanding tax liability are
0.1% registration tax also applies on the government settled by taxpayers would be considered as “closed’ for
contract value related to the supply of goods/services that any further tax audits.
are used under the state budget.
In case of strong evidence of tax evasion comprehensive audits
The following legal documents are subject to a registration can be conducted further back than 5 tax years backwards with
tax (stamp duty) of KHR1,000,000: approval from the Minister of Economy and Finance.
–– Company formation
The Director General of the GDT can order any department
–– Company merger
to conduct a special audit or investigation of criminal
–– Dissolution of a company offense on tax provisions on an enterprise if there is serious
Property Transfer Taxes evidence showing intentional tax evasion of enterprises.
There is a 4% tax on the transfer of ownership or A “committee for enterprise allocation” established by the
possession rights for immovable property or transportation GDT manages a list of enterprises and allocates them for
means (such as land, building, vehicles). tax audits for each tax year.
This 4% tax is imposed on the market value at the time Selection of enterprises for tax audits depends on the
of the transfer, which is to be determined by the Ministry following criteria:
of Economy and Finance (MEF) and payable by the party –– Risk assessment;
acquiring the ownership or possession rights and must be
paid within three (3) months from the date of the transaction. –– Result from information crosscheck;
–– Information obtained from third party;
Tax on Immovable Property (TIP)
–– Information about types of taxes or specific industries;
TIP was created in the 2010 Law on Financial Management
(LFM) and is imposed on certain immovable properties. –– Information of particular taxpayer; and
The term “immovable property” is defined as land, houses, –– Location of enterprise, etc.
buildings and constructions that are built on the land.
If the tax auditors find any grounds (i.e. under-declared tax, non-
The Prakas on the collection of the TIP was subsequently compliance...etc.), they can issue a tax reassessment notice.
issued on 19 July 2010 for implementation of the TIP. This Any reassessed tax will be subject to penalties as follows:
TIP is collected every year at the rate of 0.1% on the value
–– 10% if the taxpayer is negligent
of the immovable property that is more than the threshold
of KHR100,000,000 (approximately US$25,000). The value –– 25% if the taxpayer is seriously negligent
of the immovable property is assessed by the Assessment
–– 40% if it is a unilateral tax reassessment
Committee, which is set up by the MEF.
There is also 1.5% interest for each month for late
The deadline for paying the TIP is 30 September.
payment.
Tax on Unused Land The taxpayers will have thirty (30) working days to either
A tax is levied on unused land and the registered owner make the tax payment or submit a protest to the GDT.
of the land is responsible for the payment of the tax. Tax Taxpayers may request for settlement of tax debt in
on unused land is based on 2% of the market price per installments, provided they meet certain criteria and are
square meter as determined by the Committee for the able to provide required supporting documents.
Valuation and is due to be paid annually by 30 September.
A "Committee for Tax Arbitration (CTA)" was set up, under the
However, unused land on which ’Tax on immovable MEF. It is stated that this committee will play the role of a third
property’ has been paid is not subject to tax on unused party arbitrator if the taxpayer is dissatisfied with the GDT's
land, effective from 2011 onwards. decision on the initial protest above.
Tax Audit However, as a matter of practical reality there is limited
recourse for a taxpayer in any dispute with the GDT.
Generally, there are essentially two kind of tax audits: desk
audit and limited audits and comprehensive/final audits The detailed procedure of tax protest is described in
which are on field audits. Prakas 1470 by the MEF and Sub-Decree 03 by the Royal
Government of Cambodia.
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