Cambodia Tax Residency Guide 2026

Overview — Tax Residency in Cambodia

Tax residency determines the scope of an individual's or entity's tax obligations in Cambodia. The Law on Taxation (LoT) defines tax residency based on physical presence and economic connections. Cambodia follows a territorial tax system — residents are taxed on Cambodian-source income while non-residents are taxed only on income derived from Cambodian sources. The General Department of Taxation (GDT) administers residency determinations. Cambodia's network of over 10 Double Tax Treaties (DTTs) provides relief from double taxation and clarifies residency status for treaty purposes.

Individual Residency — 183-Day Rule

An individual is considered a tax resident of Cambodia if they meet one of the following criteria:

• Physical presence: Present in Cambodia for 183 days or more in a calendar year
• Habitual residence: Has a permanent home available in Cambodia and spends significant time there
• Centre of vital interests: Personal and economic interests are primarily in Cambodia

The 183-day test is the primary determinant. Days of presence count if the individual is in Cambodia at any time during the day. Short-term visitors, tourists, and business travellers staying less than 183 days are generally non-residents for tax purposes (unless another criterion applies).

Tax Implications of Residency

Tax residency status determines what income is taxable:

• Tax residents: Taxed on all Cambodian-source income. Foreign-source income is not actively taxed for individuals in practice, though the legal framework allows it.
• Non-residents: Taxed only on Cambodian-source income (employment in Cambodia, Cambodian rental income, Cambodian dividends, etc.)
• Corporate residency: A company is resident if incorporated in Cambodia or if its place of effective management is in Cambodia. Resident companies are taxed on Cambodian-source income.

Double Tax Treaties (DTTs)

Cambodia has over 10 Double Tax Treaties in force, covering:

• ASEAN: Singapore, Thailand, Vietnam, Laos, Myanmar, Brunei, Philippines, Indonesia
• East Asia: China, South Korea
• Other: Several additional treaties under negotiation

These treaties generally follow the OECD Model Tax Convention and provide reduced withholding tax rates on dividends, interest, and royalties. They also provide tie-breaker rules for determining residency when an individual or company is resident in both contracting states under domestic law. The treaties facilitate cross-border trade and investment by eliminating double taxation.

Residency for Expatriates

Expatriates working in Cambodia are subject to TOS on their Cambodian employment income regardless of residency status (source-based taxation for non-residents; source-based for residents too). The 183-day rule determines whether an expatriate is resident or non-resident for treaty purposes. Expatriates who are resident in Cambodia and also subject to tax in their home country may be able to claim foreign tax credit or treaty relief. Expats should carefully track their days of presence and understand their DTT position to avoid double taxation.

Corporate Residency

A company is considered a Cambodian tax resident if:

• It is incorporated under Cambodian law, or
• Its place of effective management (POEM) is in Cambodia

Resident companies are taxed on Cambodian-source income at 20% CIT. Non-resident companies with a permanent establishment (PE) in Cambodia are taxed on Cambodian-source profits attributable to the PE. Non-resident companies without a PE are subject to withholding tax on Cambodian-source income (interest, royalties, services).

FAQs

Does Cambodia tax foreign income of residents?

The Law on Taxation provides for worldwide taxation of residents, but in practice, foreign-source income of individuals is not actively enforced. Corporate residents must include foreign-source income in taxable income.

How do I prove my residency status?

Residency can be evidenced by passport stamps, visa records, employment contracts, lease agreements, utility bills, and bank statements showing presence in Cambodia for 183+ days.

Can I be resident in two countries at once?

Yes, and in such cases, the DTT tie-breaker rules determine which country has primary taxing rights. The rules consider permanent home, centre of vital interests, habitual abode, and nationality.

Do I need to pay tax on my foreign pension?

Foreign pension income received by a Cambodian resident may be taxable in Cambodia, but this depends on the specific DTT provisions. Many treaties provide that pensions are only taxable in the source country (the payer's country).

Disclaimer

This guide provides general information about Cambodian tax residency rules for the 2026 tax year. Tax laws and treaties 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.