Cambodia Corporate Tax Guide 2026

Overview — Corporate Tax in Cambodia

Corporate tax in Cambodia is governed by the Law on Taxation (LoT) and administered by the General Department of Taxation (GDT). A company is tax resident in Cambodia if it is incorporated under Cambodian law or if its place of effective management is in Cambodia. Resident companies are taxed on Cambodian-source income; non-resident companies are taxed only on Cambodian-source income. The standard tax year is the calendar year. Companies must register for tax with GDT and obtain a tax patent (business licence). Annual CIT returns must be filed by 31 March of the following year.

Standard Corporate Tax Rate — 20%

The standard corporate income tax rate in Cambodia is 20% of taxable profits for resident companies. Taxable profit is calculated as gross revenue less allowable deductions including operating expenses, depreciation, interest costs (subject to thin capitalisation rules limiting interest deductions to 130% of EBITDA), and losses carried forward. Losses may be carried forward for 5 years. Capital allowances (depreciation) are calculated at standard rates: buildings 5% straight-line, machinery 20% declining balance, computers 50% declining balance, motor vehicles 25% declining balance.

Insurance Companies — 15%

Insurance companies operating in Cambodia benefit from a reduced CIT rate of 15% on taxable profits. This lower rate applies to both life and non-life insurers. Insurance companies are also subject to specific premium-based taxes and regulatory requirements under the Non-Bank Financial Services Authority (NBFSA). The 15% rate is a significant competitive advantage for the insurance sector in Cambodia.

Minimum Tax — 1% of Gross Revenue

If the standard CIT calculated is lower than 1% of gross revenue, the taxpayer must pay the minimum tax of 1% of gross revenue. The minimum tax applies to all enterprises under the Real Regime (except for QIPs during the tax holiday period). The 1% minimum tax is calculated on gross revenue including all sales, services, and other income. It is creditable against future CIT liabilities — if standard CIT exceeds 1% in a future year, the excess minimum tax paid can be carried forward and offset.

Qualified Investment Project (QIP) Incentives

Qualified Investment Projects (QIPs) registered with the Council for the Development of Cambodia (CDC) or the Provincial-Municipal Investment Sub-Committee (PMIS) may receive significant tax incentives. QIPs benefit from a trigger period of 3–9 years (varies by sector and investment size) during which CIT is 0%. After the trigger period, QIPs pay 20% CIT, with a 25–50% reduction for an additional 3–6 years (depending on sector). QIPs also receive duty-free import of capital goods and exemption from VAT on imported inputs.

Tax Depreciation — Capital Allowances

Cambodia allows depreciation deductions on fixed assets at prescribed rates. Buildings and structures: 5% per annum (straight-line). Plant and machinery: 20% per annum (declining balance). Computer equipment: 50% per annum (declining balance). Motor vehicles: 25% per annum (declining balance). Intangible assets: amortised over the useful life. Goodwill is not amortisable for tax purposes. The straight-line method is mandatory for buildings; declining balance is required for other assets.

FAQs

When is the corporate tax filing deadline?

Annual CIT returns must be filed by 31 March following the end of the calendar year. Monthly provisional tax payments are required based on the previous year's tax liability. Late filing attracts a 10% penalty plus 1.5% monthly interest on unpaid tax.

Can a foreign company operate through a branch?

Yes, foreign companies may establish a branch in Cambodia. The branch is taxed at 20% on its Cambodian-source profits. Branches must register with GDT and obtain a tax patent. Repatriation of branch profits to the head office is subject to 14% withholding tax.

What is the thin capitalisation rule?

Cambodia limits interest deductions to 130% of EBITDA for tax purposes. Excess interest costs may be carried forward for up to 5 years. Related-party loans must follow arm's length principles. The rule applies to all enterprises under the Real Regime.

Are capital gains subject to CIT?

Yes, capital gains are included in taxable income and taxed at the standard CIT rate of 20%. However, a separate Capital Gains Tax (CGT) regime was introduced in 2024–2025 for real estate and shares sold within 5 years of acquisition.

Disclaimer

This guide provides general information about Cambodian corporate tax for the 2026 tax year. Tax laws and rates may change. Always consult with a qualified Cambodian tax advisor or the General Department of Taxation for advice specific to your situation. InvestmentKit does not provide tax advice.