Cambodia taxes residents on worldwide income and non-residents on Cambodia-source income only. Cambodia has no Controlled Foreign Company regime. Cambodia operates a self-assessment system, with the General Department of Taxation conducting post-filing review.
The Cambodian tax year is the calendar year.
Cambodia's headline corporate income tax (CIT) rate is 20%.
The headline personal income tax (PIT) rate is 20%.
The standard VAT/GST (or equivalent consumption tax) rate is 10%.
An individual present in Cambodia for 182 days or more in a 12-month period may qualify as a tax resident, but must affirmatively declare residency status to the General Department of Taxation to be taxed as one; without that declaration, the individual remains taxed at the higher flat 20% non-resident withholding rate on Cambodian-source salary regardless of actually meeting the day-count threshold. Resident taxpayers are taxed on worldwide income; non-residents and a permanent establishment are taxed on Cambodian-source income only.
A non-Cambodian entity has a Cambodia permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Cambodia on the entity's behalf, following the OECD Model Treaty definition as applied under Cambodian domestic law and any applicable tax treaty.
Cambodia has no provision for CFCs. A related-party "control" definition does exist for other anti-avoidance purposes (direct or indirect ownership of 20% or more of value or voting rights, with spousal equity interests attributed to an individual's ownership calculation, and the tax administration retaining discretion to find control based on case-specific facts) - but this is a related-party/transfer-pricing control test, not a CFC attribution mechanism.
Cambodia has no formal thin capitalization (debt-to-equity) rule. Instead, interest expense deductibility is capped at interest income plus 50% of net non-interest profit for the year, with any excess carried forward for up to five years; for related-party loans specifically, the interest rate may not exceed the market interest rate published annually by the General Department of Taxation, and any excess over that rate is non-deductible.
Cambodia does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics. Cambodia does not have a comprehensive ATAD2-style anti-hybrid regime.
No foreign bank account or foreign financial asset reporting regime exists requiring residents to separately disclose foreign accounts; foreign income is reported through the standard annual tax return.
Cambodia does not provide a broad participation exemption for foreign dividends; relief from double taxation is available primarily through Cambodia's limited treaty network and foreign tax credit provisions.
Cambodia has a foreign tax credit mechanism for foreign tax paid on foreign-source income also taxed in Cambodia, capped at the Cambodian tax otherwise due on that income.
Cambodia has approximately 12 double taxation agreements in force and is actively expanding its treaty network to attract foreign investment. Under a 2026 General Department of Taxation instruction (Instruction 23862) clarifying capital gains tax treatment under treaty frameworks, DTA provisions prevail over the domestic Law on Taxation in determining capital gains taxing rights, based on the gain-earner's source and residency - a specific, recent, well-documented example of how Cambodia's treaty network interacts with its newly-implemented capital gains regime.