The National Bank of Cambodia (NBC) issued guidelines to allow financial institutions for loan restructuring for borrowers experiencing financial difficulties (but still performing) in priority sectors (tourism, garments, construction, transportation and logistics) temporarily by the end of this year. In November 2020, NBC announced to extend the forbearance by another 6 months to the end-June 2021, taking account of the adverse impacts from the recent nation-wide flooding in addition to the COVID-19 shock. In February 2021, NBC called for banks and financial institutions to suspend dividend payments for 2020.

 (Updated: May 2022)

CIT：

(1) CIT waiving for 4 months from February to May 2020 for hotels and guesthouse businesses operating in Siem Reap Province (tourist town).

(2) Allow tax deductions for any seniority indemnity payments in the Tax on Income of any enterprises.

(3) Tax waiving on minimum tax for 3 months from March to May 2020 for Cambodia's airline companies.

(4) CIT waiving for 3 months from March to May 2020 for hotels, guesthouses, restaurants and travel agencies operating in Phnom Penh, Siem Reap, Sihanouk, Kep, Kampot, Bavet and Poipet.

(5) Hotels, guesthouses, restaurants and travel agencies operating in Phnom Penh, Siem Reap, Sihanouk, Kep, Kampot, Bavet and Poipet must file 2019 tax returns by 31 March 2020, but tax payments are allowed to do monthly installments until November 2020.

(6) Law 2010 of 2019 established a gradual reduction in the corporate tax rate, from 33% in taxable year 2019; to 32% in taxable year 2020; 31% in taxable year 2021, and to 30% as of taxable year 2022 onwards.

(7) Law 2010 of 2019 introduced a temporary surcharge for companies belonging to the financial sector whose taxable income exceeds 120.000 TVU (Taxable Value Unit) (COP 4.272 million for 2020). The surcharge is 4% in taxable year 2020, and of 3% for taxable years 2021-2022 It will be pay in advance.

(8) Law 2010 of 2019 introduced the Mega-investments regime for those taxpayers that generate at least 400 new direct jobs; or taxpayers that generate at least 250 new direct jobs in mega investments made in sectors with a high technological component, along with new investments within the national territory with a value equal to or greater than TVU 30 million (approximately to USD 289 000 000)  in any industrial, commercial and/or service activity. In this regime, the CIT rate is 27%.

(9) Law 2010 of 2019 created a new income tax credit related to the local turnover tax that taxpayers pay. This tax credit is of 50% of the turnover tax paid and as of 2022, the tax credit will be 100%.

(10) The deadline for large taxpayers for filing the 2019 income tax return has been set between 9 June and 24 June 2020 depending on the last digit of their TIN; The deadline for legal entities (not designated as large taxpayers) for filing the income tax return has been set between 1 June and 1 July 2020 depending on the last digit of their TIN.

(11)The deadline for large taxpayers for paying the second instalment of their 2019 income tax has been set between 21 April and 5 May 2020, as well as the payment of the income tax surcharge, depending on the last digit of their TIN and the deadline for paying the third instalment has been set between 9 June and 24 June 2020 depending on the last digit of their TIN;The deadline for legal entities (not designated as large taxpayers) for paying the first instalment of their income tax has been set between 21 April and 19 May 2020 depending on the last two digits of their TIN and the deadline for paying the second instalment has been set between 1 June and 1 July 2020 depending on the last digit of their TIN.

Other Corporate Taxes：Law 2010 of 2019 established the gradual elimination of the alternative minimum tax, from 3.5% of the net equity as of 31 December of the preceding tax year, for 2019, to 0,5% in 2020 and 0% as of taxable year 2021 onwards.

The SIMPLE regime was enacted by Law 2010 of 2019. It is an optional regime and replaces the income tax and the Municipal Business Turnover tax (ICA), as well as other less representative subnational taxes. It applies to businesses and self-employed who earn annual gross earnings below 80.000 TVU (USD 771.000 or COP 2.849 million) and the tax rate depending of both the taxpayer's economic activity and gross earnings brackets.

PIT:

Tax waiving on seniority indemnity payments before 2019 and tax waiving on seniority indemnity payments on 2020 for the amount below 1,000 USD.

Property taxes: Tax waiving on transfer tax for any purchases below 70,000 USD from licenced property developers effective for one year (February 2020 to January 2021).

As a result of Law 2010 of 2019, PIT was adjusted in two ways. First, the PIT tax schedule included three new taxable income brackets at the top of the table, with rates higher than the maximum rate of the previous schedule, which was applied to labor and pension income. The top PIT tax rate for these types of income was 33%, and the latest tax reform added tax rates of 35%, 37% and 39%. Second, this new PIT tax schedule is applied to taxable income arising from both the new general basket,  which is currently made up of labor, capital and non-labor income, as well as pension income, unlike the previous system where the tax liability was determined separately, depending on the type of income earned by the taxpayer. This last change would improve vertical equity and increase the taxable base, thus obtaining higher revenues.

SSCs:

Deferral of contribution to social security funds during the suspension or halt in operations for hotels, guesthouses, restaurants and Travel Agencies operating in Phnom Penh, Siem Reap, Sihanouk, Kep, Kampot, Bavet and Poipet.

Other consumption taxes: 

Fast-track customs processing ("green lane") of imports of raw materials, accessories and manufacturing components of investment projects relating to the garment production industry. Note: An importer using the green lane for customs declaration purposes obtains access automatically, with a clearance document being issued.

Reduction of consumption tax rate from 8% to 0% for restaurants and cafeterias until 31 December 2020.

VAT/GST：

VAT zero-rating on medical devices.

Donation of listed goods intended to mitigate the COVID-19 crisis will not be considered as sales for VAT purposes, unless it is donated between related parties.

Exemption of VAT for leases of commercial premises until 31 July 2020, if it had been closed totally or partially for more than 2 weeks.

Health-related taxes：For the purposes of urgent delivery due to the urgent need of the goods corresponding to vaccines against Covid-19, the requirement of the constitution of guarantee in favour of the National Tax Office will not be required

The officials of the National Tax Office can continue working from home.

Issuance of the Form No. 350 (Withholding tax) for fiscal year 2021 and following. The boxes in relation to the withholding tax of the solidarity tax and Voluntary solidarity contribution for COVID 19 where eliminated.

Other:

(1) Fee deferral of civil aviation fee for 6 months and allow installment payments upon the 6 months.

(2) Government contributes 20% to the mandated minimum wage paid to workers and employee who are working for hotels, guesthouses, restaurants and Travel Agencies operating in Phnom Penh, Siem Reap, Sihanouk, Kep, Kampot, Bavet and Poipet.

(3) Monthly allowance of 40 US dollars for workers working in the garment sector (textiles, footwear, travel products and bags), to which the employer should add 30 US dollars to each worker's allowance, amounting to a total allowance of 70 US dollars a month per employee. Workers in the tourism sector will also receive this 40 US dollars allowance and their employer are invited to top-off this sum in a voluntary manner, based on their capability. This allowance will only apply to employers that have been permitted to suspend employment contracts by the ministry of Labor.

(4) Exemption from all monthly tax payments for registered taxpayers engaged in the hotel and guesthouse business in the province of Siem Reap for the period from February to May 2020.

(Updated: August 2020)