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      Corporate taxpayers in Cambodia are classified as either resident taxpayers or non-resident taxpayers. A resident taxpayer is primarily an enterprise that has a place of management and carries on business in Cambodia, as defined below. A non-resident taxpayer is an enterprise that derives Cambodian source income but does not have a place of management in Cambodia. A non-resident taxpayer will be deemed to be a Cambodian resident for tax purposes if it is found to have a Permanent Establishment (PE) in Cambodia. A resident taxpayer is subject to Tax on Income (ToI) or Corporate Income Tax (CIT) on income derived from both Cambodian and foreign sources, whereas a non-resident taxpayer is subject to ToI/CIT in respect of its Cambodian source income only.

      Our Corporate Tax team advises organisations and provides tax compliance supports on domestic and international tax laws affecting local and cross-border transactions and other regulatory matters, such as foreign investment rules and industry-specific regulatory requirements as well as domestic tax issues such as incentives, deductibility, and corporate tax management.

      Corporate tax obligations both in Cambodia and across the globe can represent a substantial outflow of funds from a business. Expanding tax reporting requirements, and increased scrutiny by tax authorities together with the imposition of penalties for non-compliance mean that the governance of tax can absorb increasing amounts of senior management time.

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      Tax on Income (ToI) - 2026

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      Common errors in ToI calculation

       
      • Incorrect assessment of tax incentives
      • Incorrect treatment of taxable income period
      • Over-claimed deductible expenses and expenses subject to deduction limitation rules
      • Insufficient supporting documents for expenses
      • Unclear/incorrect documentation related to cross-border transactions
      • Inappropriate allocation of expenses among related parties
      • Incorrect claim of expenses within related parties
      • Incorrect claim of tax losses carried forward
      • Incorrect claim of interest expenses or interest expenses carried forward
      • Incorrect claim for capital allowance (i.e. tax depreciation)

      It is, therefore, important that you have access to the right advice and compliance support at the right time to enable you to achieve effective tax compliance and manage tax risks, whilst also controlling costs.


      How KPMG can support

      We provide end-to-end ToI compliance and risk management support, tailored to your business:

      • ToI preparation and review, including e-filing support
      • Post filing review with tax risk identification and mitigation
      • Deferred tax and ToI provision calculation
      • Review of tax incentives and confirmation of applicable tax rates
      • Multiple QIP projects and QIP/non-QIP cost allocation review
      • Historical ToI review and amend declarations support
      • Related party transaction review and transfer pricing documentation
      • Practical ToI compliance training and documentation guidelines

      Why KPMG?

      Technical Strength. Practical Insight. Defensible Positions.

      • Protect your business by ensuring accurate and compliant ToI declarations.
      • Reduce future disputes through early identification and correction of tax risks.
      • Work with industry focused teams who understand your commercial realities.
      • Leverage extensive experiences supporting companies through GDT reviews, audits, and dispute resolution process.


      Download Tax on Income Brochure here

      download

      Tax on Income (ToI) - 2026

      Download English version

      More About Us

      At KPMG, we want to support you on your journey to create an impactful career. Join us and you too can do work that matters.

      Financial statement audits give assurance over information used by investors and the capital markets.

      KPMG in Cambodia's team of specialists works at deal speed to help you find and drive value throughout your transformation and transaction lifecycle.

      Cambodia is one of the most economically friendly countries in Southeast Asia.