The determination and taxation of the Cambodian sourced income of international shipping liners has long posed problems in this dynamic Southeast Asian country. As a longstanding manufacturing hub, imports of raw materials and export of finished and semi-finished products are hallmarks of Cambodia’s robust economy. However, the taxation of shipping lines has been an area […]

This article addresses a possible misunderstanding of Cambodia’s Transfer Pricing (“TP”) regulations as set out in Prakas 986 on Rules and Procedures for Division of Income and Expense between Related Parties (“the Prakas”).

VDB Loi have recently had the opportunity to meet senior members of the GDT’s Transfer Pricing team to discuss and clarify certain issues that are not clearly addressed in the new Transfer Pricing (“TP”) regulations. These issues, and the GDT’s current thinking on them, are as follows: Will it be possible to obtain the GDT’s […]