1. Introduction

Cross-border investment depends on tax certainty. When the same income can be taxed once in the country where it is earned and again in the investor’s home country, returns fall and projects are delayed or abandoned. Double Taxation Agreements (DTAs) address this problem by allocating taxing rights between two states, limiting withholding tax at source, and providing a clear mechanism for relief.

According to the General Department of Taxation (GDT), Cambodia has now signed 15 DTAs, the most recent being with Azerbaijan on 12 October 2026. Of these, 11 are the agreements that taxpayers have been able to apply in practice; the other four are signed but still waiting for ratification and the exchange of instruments. This distinction matters: a signed treaty gives no benefit until it enters into force.

This article explains what DTAs do, which jurisdictions are covered, the main benefits for investors and businesses, and the step-by-step process for claiming treaty relief through the GDT’s online system.

2. What a DTA does

A DTA is a bilateral agreement that decides which country may tax particular types of income, and how the other country must give relief. In Cambodia’s case, the agreements serve four practical purposes:

• Allocation of taxing rights. For example, income from immovable property is generally taxed where the property is located, and business profits of a foreign enterprise are taxed in Cambodia only when it has a permanent establishment (PE) here.
• Reduced withholding tax. Cambodia’s domestic withholding tax on dividends, interest and royalties paid to non-residents is 14%. Under the DTAs in effect, the rate is generally reduced to 10%, and the same reduced rate commonly extends to technical service fees. Some treaties also exempt certain interest, such as interest paid to specified government bodies.
• Relief from double taxation. A Cambodian tax resident who has paid tax abroad on income covered by a treaty is normally allowed a tax credit in Cambodia, limited to the Cambodian tax payable on that same income.
• Cooperation and anti-avoidance. DTAs provide for exchange of information between tax authorities and help prevent tax evasion and avoidance.

The Cambodian taxes that can be covered include tax on income, withholding tax on dividends, interest and royalties, minimum tax, additional tax on dividend distributions, and tax on salary. Each treaty has its own wording, so PE rules, reduced rates and covered taxes differ from one agreement to another. For instance, the China treaty uses a nine-month threshold for a construction or similar PE and has no service PE provision, while the Singapore treaty uses a six-month threshold.

3. Cambodia’s DTA network

3.1 Agreements applied in practice (11)

No.	Jurisdiction
1	China
2	Singapore
3	South Korea
4	Malaysia
5	Hong Kong
6	Vietnam
7	Indonesia
8	Brunei
9	Thailand
10	Turkey
11	Macau

3.2 Signed but not yet in effect

No.	Jurisdiction	Signed	Status
12	Laos	4 December 2024	Approved by the Council of Ministers on 24 October 2025; entry into force follows the exchange of ratification instruments
13	Philippines	11 February 2025	Approved by the Council of Ministers on 24 October2025; entry into force follows the exchange of ratification instruments
13	Philippines	11 February 2025	Approved by the Council of Ministers on 24 October 2025; entry into force follows the exchange of ratification instruments
14	Myanmar	11 September 2026	Awaiting ratification by both countries
15	Azerbaijan	12 October 2026	Awaiting ratification by both countries; Cambodia’s first treaty partner in the Caucasus region

Taxpayers should confirm the current entry-into-force status with the GDT before relying on any of these four agreements.

4. Key benefits

For foreign investors in Cambodia. The reduction of withholding tax from 14% to a treaty rate, commonly 10%, lowers the cost of repatriating dividends, paying interest on cross-border loans, and remunerating royalties and technical services. The treaty also gives clarity on when a foreign enterprise creates a taxable presence in Cambodia.

For Cambodian residents investing abroad. Residents can apply for a certificate of residence and for a tax credit for foreign tax paid, which prevents the same income bearing full tax in both countries.

For tax certainty and dispute prevention. Treaties set out agreed rules and cooperation between tax authorities, which reduces uncertainty for long-term investment decisions.

For capital gains. On 4 August 2025 the GDT also issued Instruction No. 23862 on the implementation of capital gains tax under DTAs. Share and asset transactions involving treaty-country residents should be reviewed against it.

5. How to apply for DTA benefits

Under GDT Instruction No. 23869 (dated 4 August 2025), applications are made entirely online through the DTA Implementation Management System on the GDT e-Services portal. The system covers requests for certificates of residence, for DTA tax rates, and for tax credits. The steps below use a Malaysian tax resident as the example.

1. Access the system. Go to the GDT website (www.tax.gov.kh/en/e-service), click the “DTA Implementation Management System” icon, and log in with your GDT account, or create one if you do not have it.
2. Select the application type. Choose “Request for DTA Tax Rate” (DTA) and complete the details of the income and the parties involved.
3. Attach supporting documents. The most important document is the Certificate of Tax Residency (CoR) issued by the tax authority of the treaty country. For a Malaysian resident this is the certificate from the Inland Revenue Board of Malaysia (LHDN), confirming tax residency for the relevant period. Contracts, invoices and proof of payment may also be required.
4. Submit and track. Check the information, click “Submit”, and follow the status of the application with the GDT Check & Track app by scanning the QR code on the application form.
5. Receive approval. Once approved, the GDT notifies the applicant by email with a code. Log back into the system to print the official Notification Letter on the Granting of DTA Benefits. Its authenticity can be verified through the same QR code.

6.  Resolving disputes: the Mutual Agreement Procedure (MAP)

When a taxpayer believes tax has been or will be charged contrary to a treaty, the Mutual Agreement Procedure (MAP) lets the tax authorities of the two countries settle the matter between themselves. Cambodia’s tax treaties generally contain a MAP article, modelled on Article 25 of the UN Model Convention, and the GDT has issued a Prakas (2021) confirming how MAP applies under them.

When MAP is relevant

• The same income is taxed in both countries despite the treaty.
• Tax or withholding is charged at a rate higher than the treaty allows, or a reassessment is not in line with the treaty.
• The two countries read the treaty differently, for example on residence, permanent establishment or the character of income.

How the procedure works in Cambodia

1. The taxpayer files an objection letter with the Cambodian competent authority (the GDT), based on the MAP article and within the time limit in the treaty, with supporting documents.
2. The competent authority checks eligibility, may ask for more documents, and may reject a letter filed out of time.
3. It first considers whether it can resolve the issue on its own, for example by amending the reassessment notice.
4. If it cannot, it consults the competent authority of the other treaty country.
5. The taxpayer is notified in writing of the outcome. If the taxpayer accepts it, the competent authority implements it.

MAP is a negotiation between governments, so an agreement is not guaranteed. And treaty time limits, which usually run from the first notice of the action, are strict, so a MAP request should be coordinated with domestic objection and appeal deadlines. MAP is available only under treaties that are in force.

7. Practical points for taxpayers

• Obtain approval before applying the reduced rate. The GDT’s long-standing rule is that treaty benefits require prior approval, so the payer should not apply a reduced withholding rate on its own assessment.
• Do not assume 10%. The rate, the income covered and any exemptions depend on the specific treaty. Read the relevant articles for dividends, interest, royalties and technical services.
• Keep the residence certificate current. The CoR must cover the period in which the income is paid, so plan renewals ahead of payment dates.
• Check the beneficial owner. Treaty benefits are intended for the genuine recipient of the income. Conduit or purely formal structures invite challenge.
• Keep complete records. Retain the contract, invoices, proof of payment, the CoR and the GDT notification letter for audit purposes.
• Review PE exposure. Foreign enterprises sending staff or contractors to Cambodia should test the project duration and activities against the treaty’s PE article.

8. Outlook

The network is still growing. The GDT has stated that Cambodia has completed negotiations with France and continues negotiating with Japan, Morocco, the United Arab Emirates and Qatar. Once ratified, these agreements will extend treaty protection to some of Cambodia’s most important investment and trade partners and will further support the Kingdom’s competitiveness for foreign direct investment.

9. Conclusion

Cambodia’s DTA network has expanded from the first two treaties effective in 2018 to 15 signed agreements in 2026. The benefits are real: lower withholding tax, credit relief, clearer PE rules and stronger tax certainty. But they are only available to taxpayers who follow the procedure: confirm that the treaty is in force, obtain the residence certificate, apply through the GDT’s online system before the payment, and keep full documentation. Businesses with cross-border payments should review their transactions now so that treaty relief is claimed correctly and on time.

This article provides general information only and is not tax advice. Treaty provisions and GDT procedures change; please confirm the current position with the GDT or a qualified tax adviser before acting.

Cam Accounting & Tax Service Co., Ltd., a member firm of Kreston Global, holding a GDT tax agent license, Accounting, Auditing, and liquidator licenses from ACAR, and accredited by the National Bank of Cambodia (NBC) and Trust Regulator (TR).

For more information, please contact our Accounting, Tax and Audit Expert

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