Double Taxation Agreements Cambodia 2026
Cambodia has signed Double Taxation Agreements with 12+ countries to prevent the same income being taxed twice. This guide covers every treaty partner, withholding tax rates, how to claim DTA benefits, and strategies for investors from non-treaty countries.
Cambodia DTA Treaty Countries Table
Withholding tax rates under Cambodia's DTAs compared to domestic rates (14% for non-residents):
| Country | Signed | Dividends | Interest | Royalties | Notes |
|---|---|---|---|---|---|
| China | 2016 | 10% | 10% | 10% | Most used DTA. Covers Hong Kong separately. Significant Chinese investment in Cambodia. |
| Singapore | 2018 | 10% | 10% | 10% | Important for holding company structures. Singapore is a major investor in Cambodia. |
| Thailand | 2017 | 10% | 10% / 15% | 10% | Key for cross-border trade businesses. Interest rate depends on recipient type. |
| Vietnam | 2018 | 10% | 10% | 10% | Important for Bavet SEZ cross-border operations. Growing bilateral trade. |
| South Korea | 2019 | 10% | 10% | 10% | Significant Korean garment and manufacturing investment in Cambodia. |
| Japan | 2020 | 10% | 10% | 10% | Major investor. Auto parts, electronics. Strong bilateral investment protection. |
| Indonesia | 2018 | 10% | 10% | 10% | ASEAN neighbor. Growing investment relationship. |
| Malaysia | 2018 | 10% | 10% | 10% | ASEAN partner. Plantation and construction sector investments. |
| Brunei | 2017 | 10% | 10% | 10% | Limited bilateral investment but strategic ASEAN relationship. |
| India | 2019 | 10% | 10% | 10% | Growing IT services and pharmaceutical investment from India. |
| Bangladesh | 2019 | 10% | 10% | 10% | Garment sector bilateral relationship. |
| Hong Kong SAR | 2020 | 10% | 10% | 10% | Separate from China DTA. Important for HK holding structures. |
How DTAs Work
Countries Without a DTA
No DTA: US, UK, Australia, Canada, EU Countries
Cambodia does not currently have DTAs with the US, UK, Australia, Canada, France, Germany, or most EU countries. Investors from these countries face the full 14% domestic withholding tax on dividends, interest, and royalties.
Options for non-treaty investors: (1) Check if your home country offers unilateral foreign tax credit relief for Cambodian taxes paid, (2) Consider structuring through a DTA jurisdiction (Singapore, Hong Kong) with genuine substance, (3) QIP tax holiday eliminates the need for DTA benefits during the incentive period, (4) Lobby efforts are ongoing for Cambodia to expand its DTA network.
Frequently Asked Questions
Does Cambodia have a DTA with the US, UK, or Australia?
No. As of 2026, Cambodia does not have Double Taxation Agreements with the United States, United Kingdom, Australia, France, Germany, or Canada. This means cross-border payments between Cambodia and these countries are subject to full domestic withholding tax rates (14% for non-residents). For investors from these countries, structuring through a DTA jurisdiction (e.g., Singapore or Hong Kong holding company) may reduce the overall tax burden, provided the holding company has genuine substance and is not established solely for treaty shopping purposes. Cambodia is actively negotiating additional DTAs.
How do I claim DTA benefits in Cambodia?
To claim reduced withholding tax rates under a DTA: (1) The income recipient must obtain a Certificate of Tax Residence from their home country's tax authority — this proves they are a tax resident of the treaty partner country. (2) The Cambodian payer submits the Certificate of Residence to the GDT along with the withholding tax return. (3) The reduced DTA rate is applied at the time of withholding — you do not need to withhold at the domestic rate and then seek a refund. (4) GDT may request additional documentation including the underlying contract, proof of beneficial ownership, and evidence that the recipient is the beneficial owner (not an agent or conduit). Processing is generally straightforward for well-documented claims.
What is treaty shopping and is it allowed?
Treaty shopping refers to routing investments through a DTA jurisdiction solely to access reduced tax rates, without genuine business purpose in that jurisdiction. Cambodia's GDT is aware of treaty shopping and can deny DTA benefits under the "beneficial owner" test — the recipient of income must be the true beneficial owner, not merely a conduit. The OECD BEPS (Base Erosion and Profit Shifting) framework, which Cambodia follows informally, provides guidance on anti-abuse provisions. To sustain DTA claims, your holding company or intermediary entity should have: genuine business activities, real employees, physical office space, and decision-making authority in the treaty jurisdiction.
How are dividends from Cambodia taxed for foreign shareholders?
Dividends paid by a Cambodian company to foreign shareholders are subject to withholding tax: (1) Domestic rate (no DTA): 14% withheld at source, (2) DTA rate (most treaties): 10% withheld at source. The dividend withholding tax is a final tax in Cambodia — the foreign shareholder has no additional Cambodian tax obligation. In the shareholder's home country, the dividend will typically be subject to income tax, but a foreign tax credit is usually available for the Cambodian withholding tax paid. Under most DTAs, the credit mechanism prevents double taxation. For countries without a DTA with Cambodia, check whether your home country provides unilateral foreign tax credit relief.
Does the DTA affect salary tax for expat employees?
Yes. DTAs typically provide that employment income is taxable only in the country where the work is performed, unless the employee is present for fewer than 183 days in a 12-month period AND is paid by a non-resident employer AND the salary is not borne by a permanent establishment in Cambodia. For most expats working full-time in Cambodia, salary tax is payable in Cambodia regardless of DTA status. However, the DTA prevents double taxation by requiring the home country to provide a credit or exemption for Cambodian salary tax paid. Short-term secondees and business visitors may benefit from the 183-day exemption.
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Legal Disclaimer: DTA rates and provisions are subject to treaty interpretation and may change. Consult a licensed tax advisor for specific application of treaty benefits.
Our legal content is developed in partnership with licensed Cambodian attorneys and business consultants who specialise in foreign investment, immigration, and property law.
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