Cambodia’s tax landscape did not see a wave of brand-new laws in 2026. Instead, the General Department of Taxation (GDT) and the Ministry of Economy and Finance (MEF) spent the year consolidating and operationalizing reforms introduced in 2024–2025 — capital gains tax, transfer pricing, and e-invoicing chief among them — while adding targeted relief measures for specific sectors. For businesses operating in Cambodia, 2026 is best understood as a year of implementation, clarification, and enforcement rather than legislative overhaul.

Below is a briefing on the developments that matter most.

Standard Rates at a Glance (2026)

Tax Type	Rate
Corporate Income Tax (standard)	20%
Capital Gains Tax	20% flat
VAT (standard)	10%
VAT on fuel (temporary, from March 2026)	4%
Personal Income Tax (Tax on Salary)	Progressive, 0–20%
QIP incentive (CDC-registered projects)	Up to 0% corporate tax for up to 9 years

(QIP incentives, exemptions, and reduced rates depend on sector, investment size, and CDC registration terms — always verify against the specific project’s registration certificate.)

1. Capital Gains Tax (CGT) Moves Into Full Effect

The CGT regime introduced under Prakas No. 496 MEF.Prk (18 July 2025) reached its next major milestone in 2026:

• Leases, investment assets, goodwill, intellectual property, and foreign currency gains have been taxable since 1 September 2025.
• Immovable property (real estate) gains became taxable from 1 January 2026.
• The tax applies a flat 20% rate, with resident individuals taxed on worldwide capital gains and non-residents taxed only on Cambodia-sourced gains.
• Taxpayers must file and pay CGT within three months of realizing the gain; a transfer of ownership is not considered legally complete until the CGT liability is settled.

In late 2025, the MEF followed up with Prakas No. 1130 MEF.Prk.GDT (31 December 2025) and the accompanying Instruction No. 022, which clarified several practical points that had been ambiguous in the original Prakas:

• Withholding tax treatment on retained earnings for share transfers by non-residents.
• Rules on deductible costs for share and property transfers.
• Guidance on determining fair market value and worked examples for the CGT declaration process under the self-assessment regime.

GDT Instruction No. 23862 additionally confirmed that Double Taxation Agreement (DTA) provisions override the domestic Law on Taxation in determining which country has taxing rights over a capital gain — an important point for foreign investors structuring exits.

Practical note: Firms advising on property sales, share transfers, or exits from Cambodian investments should now treat CGT compliance as a standard closing item, not an emerging risk.

2. Transfer Pricing: Prakas 574 Enforcement Matures

Prakas No. 574 MEF.Prk.GDT, effective since 1 January 2025, remains the governing framework for related-party transactions. Through 2026, GDT activity has shifted from rule-setting to enforcement and engagement:

• The GDT held a round-table discussion on transfer pricing with BDO (Cambodia), signaling closer coordination with the Big Four/mid-tier advisory community on TP audit approach.
• Benchmark interest rates for related-party loans were updated as part of the 2026 regulatory batch, directly affecting thin-capitalization and interest-deductibility calculations for group financing arrangements.
• Penalty provisions under Article 19 of Prakas 574 — aligned with the tougher penalty regime in the 2023 Law on Taxation — remain a significant exposure for taxpayers with material related-party transaction volumes and weak documentation.

Practical note: Groups with intercompany service fees, management charges, or financing arrangements involving Cambodian entities should ensure TP documentation is current and reflects the 2026 benchmark rates, not outdated 2024 figures.

3. CamInvoice: E-Invoicing Expands Toward the Private Sector

Cambodia’s centralized e-invoicing platform, CamInvoice, continued its phased rollout in 2026:

• Phase 1 (2024–2025): Mandatory for business-to-government (B2G) transactions with national-level ministries under the central budget; voluntary for B2B.
• Phase 2 (2025–2026): B2G mandate expanded — via Circular No. 003 and No. 012 — to cover 14+ ministries, including Commerce, Industry, Agriculture, Education, and Civil Service. Sub-national government entities and a defined group of private-sector taxpayers (expected to be large taxpayers or high-risk sectors) are slated to be brought into the mandatory net during this phase.
• Phase 3 (2027 and beyond): Full compliance expected for all government entities and a broader range of businesses, with B2C integration anticipated thereafter.

As of now, general B2B e-invoicing remains voluntary, but the direction of travel is clear: businesses that adopt CamInvoice early gain instant invoice validation, blockchain-backed record integrity, and are better positioned when the mandate is extended to their sector.

Practical note: For clients supplying any of the 14+ mandated ministries, CamInvoice registration is no longer optional. For others, early voluntary adoption is a reasonable audit-readiness and efficiency measure ahead of the expected 2026–2027 B2B mandate expansion.

4. Relief Measures and Administrative Adjustments

Several taxpayer-friendly adjustments came through in 2026, reflecting the government’s balancing act between revenue mobilization and cost-of-living/business-cost pressures:

• Suspension of Prepayment of Tax on Income (PToI) extended until the end of 2028, easing monthly cash-flow burdens for self-declaration taxpayers.
• State-borne VAT on basic food items, aimed at cushioning household living costs.
• VAT relief on petroleum products, including a reported cut in VAT on fuel to 4% from March 2026, and temporary reductions of gasoline/diesel taxes amid regional energy price volatility.
• Continued incentives for voluntary amendment of tax declarations, allowing taxpayers to correct prior filings with reduced penalties — useful for clients cleaning up historical exposures before an audit cycle begins.
• Tourism sector incentives and agriculture sector tax incentives, part of the government’s push to diversify growth beyond garments and construction.
• New rules on invoicing for international waterway transport and controls on alcohol/sugar-sweetened beverage promotions, both narrower but relevant for affected sectors.
• Reminders on property tax and unused land tax compliance for the 2026 filing cycle.

6. What This Means for Businessman

1. CGT compliance is now routine, not exceptional — real estate and investment transactions closing in 2026 must factor in the 20% CGT and the three-month filing window.
2. Transfer pricing documentation needs a refresh — updated benchmark interest rates and continued GDT–advisory engagement suggest audit activity in this area will intensify, not ease.
3. E-invoicing readiness is a competitive and compliance issue — suppliers to government entities must comply now; others should treat 2026–2027 as the window to prepare systems and staff.
4. Relief measures create planning opportunities — the PToI suspension through 2028 and the voluntary-amendment incentive are worth flagging proactively to clients with legacy filing issues or cash-flow constraints.
5. Sector-specific incentives (tourism, agriculture) may open new advisory engagements for firms with clients in those industries.

Outlook

With relatively few wholly new laws issued in 2026, the GDT’s focus appears to be consolidating enforcement infrastructure — e-filing, e-invoicing, and TP documentation — ahead of a likely acceleration in audit intensity once these systems reach maturity around 2027. Businesses and their advisors should treat 2026 as the year to close compliance gaps before enforcement catches up with the digital infrastructure now in place.

This memorandum is prepared for general informational purposes only and does not constitute tax, legal, or professional advice. Please contact Cam Accounting & Tax Service Co., Ltd. before acting on any matter discussed herein.

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
Partner
Chinese Line: +855 89 777 589
English line: +855 93 33 5158

Mr. Keat Heng, ACCA, CPA, FCCA
Partner
Mobile: +855 12 753 257
E-mail : info@krestoncambodia.com
Website: www.krestoncambodia.com