The Ministry of Economy and Finance (“MEF”) has introduced a new package of measures concerning stamp duty on transfers of ownership or possessory rights over immovable property under MEF Notification No. 008, issued in August 2026. The measures provide targeted stamp duty relief and administrative support for certain property transfers, building on earlier measures introduced to support Cambodia’s real estate sector and facilitate property formalization as below.
Measure 1 — Suspension of additional tax for delayed stamp-duty payment
The Government provides relief by suspending the application of additional tax arising from late payment of stamp duty where the relevant land-transfer or forwarding document has remained outstanding for more than three months from the date of issuance by the Municipal/Provincial Department of Land Management, Urban Planning, Construction and Cadastral Affairs.
The additional tax concerned is a penalty equivalent to 100% of the stamp duty payable. The suspension is to remain applicable until the end of 2027. This measure is particularly relevant to taxpayers whose administrative processing has taken longer than three months.
Measure 2 — Extension of the one-time final stamp-duty payment mechanism
The notification permits an extension of the validity of Council of Ministers Notification No. 367 dated 2 May 2017. That earlier measure allowed property owners whose properties had experienced multiple successive transfers of possessory rights to settle the stamp duty one final time, rather than requiring tax treatment based on every historical transfer.
The new notification extends this arrangement to the end of July 2026, according to the wording of the uploaded document and the published report reproducing the Government’s measure.
Measure 3 — Treatment of the final construction for stamp duty and property tax
The notification also allows taxpayers to pay stamp duty and property tax relating to the latest construction existing on the property, provided that the taxpayer has either:
- a construction permit; or
- certification from the competent authority confirming the date on which the construction was completed.
This is an important administrative simplification because some properties have construction histories that are difficult to document. The measure allows the tax administration to rely on the latest documented construction rather than requiring taxpayers to reconstruct every historical stage of development.
Measure 4 — Stamp-duty exemption for certain military personnel and national police
A particularly important new social measure is the exemption from stamp duty on the transfer of ownership or possessory rights over immovable property where the property owner is a military personnel member or national police officer who participated in frontline operations.
The exemption is conditional upon the relevant unit providing documentation confirming the person’s identity and official role or duties. The exemption therefore appears to be status-based and documentation-based, rather than a general exemption available to all military or police personnel.
Finally, the notification states that the relief does not operate retroactively in respect of taxes, including administrative penalties, additional tax and interest, that have already been paid.
Key changes with Previous Stamp Duty Measures
The new measures should be considered in the context of Cambodia’s progressive expansion of stamp duty relief.
Notification No. 014 MEF dated 9 October 2024 provided continued stamp duty incentives for qualifying real estate transactions, including a US$70,000 deduction from the stamp duty base for certain qualifying borey transactions.
Notification No. 020 MEF dated 31 December 2024 introduced a more substantial incentive for first-time homebuyers. Qualifying residential property valued at US$210,000 or less could benefit from full stamp duty exemption, while property exceeding US$210,000 could benefit from a US$210,000 deduction from the stamp duty base.
Notification No. 001 dated January 2026 subsequently extended these residential stamp duty incentives through 31 December 2026, including the US$210,000 first-time-homebuyer relief and US$70,000 relief for qualifying subsequent purchases.
The August 2026 notification is broader in scope. Rather than focusing primarily on stimulating new residential purchases, it also addresses property formalization and tax administration.
| Regulation | Main stamp duty measure |
| Notification No. 367 (2017) | Final stamp duty settlement for qualifying historical possessory transfers |
| Notification No. 014 (2024) | US$70,000 stamp duty deduction for qualifying transactions |
| Notification No. 020 (2024) | US$210,000 exemption/deduction for qualifying first-time homebuyers |
| Notification No. 001 (2026) | Extension of previous residential stamp duty incentives |
| August 2026 MEF notification | Stamp duty relief and administrative support for certain property transfers, building construction treatment and front-line military/police targeted exemption |
Practical Tips
Taxpayers should carefully determine which stamp duty relief applies to their particular transaction. Key considerations include:
- the value and type of property;
- whether the buyer qualifies for a residential-property or first-time-homebuyer incentive;
- the date and history of previous possessory transfers;
- availability of construction permits or competent-authority certification; and
- whether the taxpayer qualifies for the specific military or national police exemption.
Importantly, stamp duty relief should not be interpreted as a general cancellation of stamp duty. Where an exemption or concession does not apply, the normal stamp duty rules continue to apply.
In conclusion, for businesses, property developers, purchasers and tax advisers, the key consideration is to assess each transaction against the specific eligibility requirements and effective dates of the applicable regulation.
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
Ms. Haing Sivtieng, MIPA, MBA
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