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      This new Instruction establishes the guiding principles for manufacturers, importers, and distributors of alcoholic products and sugary beverages in Cambodia, in the context of providing prizes, and trade discounts.

      Below are the salient provisions of the new Instruction: 

      Description

      Details

      Prohibited Prize Offerings/ Activities [Article 1]

      • Offering or exchanging prizes through bottle caps, ring-pulls, or any other forms attached to cans, bottles, packaging (e.g., raffle, scratch cards, coupons, prize exchange cards, QR codes, other digital programs, etc.).

      o   This activity must cease by 30 September 2026.

      o   From 29 June 2026, impacted enterprises must cease ordering, importing, or producing new ring-pulls, bottle caps, or packaging that contain/place prizes in the product packaging.

      • Distribution or giveaway of alcoholic products and sugary beverages ‘free of charge

       

      Trade discounts for alcoholic products and sugary beverages [Article 2]

      •  Providing “trade discounts” to promote or encourage sales shall be limited to not more than 15% of the invoiced selling price.
      •   If the products are sold close to their expiration date (i.e., expiration date within 60 days), the trade discount shall be not more than 25% of the invoiced selling price. In this case, the taxpayer must notify the GDT.

      Other prizes and benefits  [Article 3]

      • In lieu of providing alcoholic products and sugary beverages, other prizes, or benefits (in kind) may also be provided (e.g., glasses, umbrellas, ice buckets, water bottles, shirts, hats, or tour packages, etc.). The value of these benefits shall not exceed 5% of the invoiced selling price. 

       

       

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      TU-Instruction no. 011-Alcohol and sugary beverages control


      Our comments:

      Over the past few years, competition among alcoholic and sugary beverage companies in Cambodia has intensified. Marketing campaigns aimed at increasing sales have largely been driven by promotional activities such as ring-pull prizes, free goods, trade discounts, and other similar incentives. While these mechanisms help businesses remain competitive, they also create challenges from a tax perspective, particularly regarding the monitoring and implementation of the applicable tax treatment of such promotions.

      This new Instruction provides much-needed guidance by clarifying what types of prize offerings and promotional activities are permissible. It also establishes limitations and benchmarks for determining what may be considered a reasonable level of prizes, trade discounts, and other incentives. Taxpayers intending to implement these types of incentives and marketing programs are encouraged to seek professional advice to ensure compliance with the applicable tax regulations, effectively manage potential tax risks, and identify any available tax planning opportunities.

      As committed tax advisors to our clients, we welcome any opportunities to discuss the relevance of the above matters to your business.


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      TU-Instruction no. 011-Alcohol and sugary beverages control