The Cambodian General Department of Taxation (GDT) has issued a notification on guidelines for the application of its tax treaties. Cambodia currently has a limited number of treaties but is working to expand its network, with five treaties signed in recent years and the first two effective from 1 January 2018 (with Singapore and Thailand).
The guidance provides a general overview of the application of tax treaties in terms of persons and taxes covered, and also sets out the rules for the application of treaty benefits. This includes that in order for treaty benefits to apply, documentation must be provided confirming that the person claiming a treaty benefit is the beneficial owner of the relevant income, as well as documentation issued by the relevant competent authority confirming the residence of the person in the relevant country. The guidance also provides that pre-approval is needed from the GDT prior to treaty benefits being claimed on Cambodian source income, including with respect to reduced withholding rates and the tax exemptions/reduction for income from international transport.
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