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Cambodia – indirect tax guide

Cambodia – indirect tax guide

Explore the requirements and rules that apply to indirect taxes in Cambodia.

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General

Type of indirect tax:

VAT.

Standard rate:

10 percent.

What supplies are liable to the standard rate?

Supplies of goods and services in Cambodia and imported goods.

Are there any reduced rates, zero- rates or exemptions and if so, what do they apply to?

Zero rate applies to exported goods and services and certain charges in relation to the international transportation of people and goods. Also, this zero-rating is applicable for any goods and services supplied by Supporting Industry Qualified Investment Projects (QIPs)/contractors to certain export industries. VAT on the supply and import of certain agricultural products shall be borne by the State (i.e. State Charges).

The zero rate for exported services applies where such services are performed outside of Cambodia or effectively used outside of Cambodia, and the services must not be for business purposes or with an economic interest in Cambodia. Documents such as contracts, bank statements, invoices, etc., must also be maintained to prove the zero-rating treatment and for the tax administrations review.

Exempt supplies include public postal services; certain medical and dental goods and services; wholly state-owned public transportation services; insurance services; primary financial services; educational services; importation of articles for personal use that are exempt from customs duties; non-profit activities in the public interest recognized by the Ministry of Economy and Finance; supplies of unprocessed agricultural products; supplies of electricity; supplies of water for public consumption and solid and liquid trash collection or cleaning services.

VAT/GST registration

Who is required to register and what is the threshold?

An enterprise that is making taxable supplies, if it falls under one of the following criteria:

  • all types of corporation, importer-exporter and investment enterprises
  • any other enterprise with turnover in respect of goods sold exceeding 125 million Cambodian riel (KHR) or in respect of services exceeding KHR60 million for the preceding 3 consecutive months or in the next 3 consecutive months
  • any enterprise that, at the beginning of any 3 consecutive months, has any government contracts that will produce taxable turnover exceeding KHR30 million

Is voluntary registration possible?

Yes.

Is voluntary registration available for an overseas company or a fiscal representative?

No.

VAT/GST compliance

What is the typical frequency of returns?

Monthly.

VAT/GST recovery

Are there any items that a registered business cannot recover VAT on?

Yes, VAT generally cannot be recovered when incurred in making exempt supplies; for non-business related purposes (such as entertainment); purchases or imports of automobiles; and purchases or imports of certain petroleum products.

Can an overseas company recover VAT if it is not registered?

No.

How long does it typically take to obtain a VAT refund following a return filing?

The VAT regulation provided a specific timeframe based on the amount of the refund and category of the taxpayer (such as gold/silver/normal taxpayers).

However, in practice, the time taken to obtain the VAT refund is very time-consuming as a VAT refund audit is required to be conducted by the tax office prior to approving the refund.

Invoices

Are there specific requirements for the content of invoices to be considered valid for VAT purposes?

Yes, valid VAT invoices shall disclose the name, address and VAT number of both the supplier and the customer; invoice date and invoice number; description of the supplies and the selling price before VAT; VAT amount; and signature of both the supplier and customer.

Moreover, VAT invoices are required to be issued in sequential order and in Khmer language (with English as a secondary language, if required). Finally, amounts on VAT invoices may be denominated in USD, while the total invoice amounts must also be denominated in KHR.

Special indirect tax rules

Does a reverse charge or indirect tax withholding mechanism apply?

No.

Rulings

Is it possible to apply for formal or informal advance rulings from the tax authority?

There is no formal or binding ruling system in Cambodia.

A taxpayer can submit a letter seeking a ruling, but the tax office is usually reluctant to respond or does not respond at all. Obtaining a ruling from the tax office is likely to be a time-consuming process. Likewise, the tax authority is reluctant to give an informal opinion or ruling.

Other indirect taxes

Are there any other indirect taxes that apply in the jurisdiction?

Other indirect taxes include the following:

  • accommodation tax
  • specific tax on certain merchandise and services
  • tax for public lighting.

Contacts

Michael Gordon / Mona Tan KPMG in Cambodia T: +855 23 216 899 E: mgordon@kpmg.com.kh / tmona@kpmg.com.kh

Disclaimer

All information within this guide is provided by KPMG professionals in Cambodia and based on information available as of September 2019.

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