Cambodia Annual Corporate Tax Compliance Guide

Who Must File Annual Compliance Reports in Cambodia?

• Private limited companies (LLCs): All locally incorporated LLCs must file annual tax returns, submit an Annual Declaration of Commercial Enterprise (ADCE) to the Ministry of Commerce, and lodge financial statements with ACAR.
• Foreign company branches: Subject to Tax on Income (TOI) for Cambodian-sourced income only, along with full GDT monthly filing obligations.
• Representative offices: Required to register with the GDT and file monthly declarations, though not engaged in direct revenue-generating activity.
• Qualified Investment Projects (QIPs): Must file a Certificate of Compliance with the Council for the Development of Cambodia (CDC) annually, in addition to all standard filings.
• Public Interest Entities (PIEs): Banks, insurance companies, listed entities, and microfinance institutions face the strictest audit and reporting obligations, including mandatory independent audits each year.
• Small taxpayers (turnover between KHR 250 million and KHR 1,000 million or KHR 1,600 million): Exempt from ACAR financial statement submission but still required to file monthly GDT declarations and the annual TOI return.
• Non-profit organizations (NPOs): Must submit financial statements to ACAR following CIFRS for NFPEs standards, on the same deadlines as other non-audited entities.

Exemptions: True exemptions are limited. Inactive entities still file ADCE, and tax obligations depend on whether any taxable activity exists. 

Annual Compliance Snapshot: Key Deadlines at a Glance

1. Annual Return / Confirmation Statement (ADCE)

• Purpose: Confirms entity particulars, directors, shareholders, and operational status to the MOC, keeping the commercial register accurate and current.
• Due date: Within 90 days after the completion of the 12th month following your company’s registration or re-registration anniversary date.
• Filing platform: Since 2024, ADCE filings are submitted exclusively through the CamDX system at registrationservices.gov.kh using your company’s CamDX account. The MOC’s own portal no longer accepts ADCE submissions.
• Portal steps: Log into your CamDX account, navigate to the ADCE module, confirm or update all entity information (directors, shareholders, registered address, business activity), and submit. Monthly reminder emails are sent to your registered MOC email address, so make sure that address is active.
• Filing fee: No government fee for ADCE filing itself, but late submission triggers a penalty of KHR 2,000,000 (approximately USD 500) per year of non-compliance.
• Additional requirement: All LLCs incorporated in Cambodia must appoint a corporate secretary who is a permanent resident of Cambodia, per the 2022 amendments to the Law on Commercial Enterprises.

2. Corporate Income Tax Return

• CIT rate: The standard Tax on Income (TOI) rate is 20% on net taxable profit for medium and large taxpayers. Companies in petroleum or natural resource extraction pay 30%. Qualified Investment Projects (QIPs) are entitled to partial tax exemptions and a tax holiday of up to 6 years. 
• Filing deadline: March 31 each year for calendar-year taxpayers (within 3 months of financial year-end for those with non-standard fiscal years).
• E-filing procedure: All self-assessment taxpayers must file electronically via the GDT’s e-filing portal. The TOI return must include a balance sheet, profit and loss account, and an annexed list of all related party transactions conducted during the year.
• Transfer pricing (new from 2025): Companies with related party transactions must now also prepare a local transfer pricing file under Prakas 574, introduced in September 2024 and effective from January 1, 2025. This is the first year of full implementation, so if your business has intercompany transactions, factor in additional preparation time.
• Payment schedule: TOI payment is due simultaneously with the filing, by March 31. The GDT imposes penalties and interest immediately on late payments.
• Patent tax: Separate from TOI, this annual business registration fee is also due by March 31. Large taxpayers pay USD 750 if annual turnover is below USD 2.5 million, and USD 1,250 if it exceeds that threshold.

3. Audited or Unaudited Financial Statements

Audit is mandatory for your entity if it meets any of the following:

• It is a public enterprise or a public limited company
• It is a Public Interest Entity (PIE): banks, MFIs, insurance companies, listed entities, securities firms
• It is a Qualified Investment Project (QIP) registered with the CDC
• It meets two out of three of the following quantitative thresholds at year-end:
  • Total assets exceed KHR 3 billion under Prakas 563 (2020)
  • Annual turnover exceedsannual turnover above KHR 4 billion
  • Average headcount exceeds 100 employees

Accepted accounting standards:

• CIFRS (full IFRS equivalent) for large enterprises and PIEs
• CIFRS for SMEs for medium-sized entities
• CIFRS for NFPEs for non-profit organizations

Submission deadlines to ACAR:

• Unaudited financial statements: By April 15 each year (3 months + 15 days post year-end). In 2025, this moved to April 20 due to the Khmer New Year holidays.
• Audited financial statements: By July 15 each year (6 months + 15 days post year-end).
• For 2025 year-end financials, the respective deadlines are April 15, 2026, and July 15, 2026.

Language and currency: Accounting records must be kept in Khmer and Cambodian Riel. Foreign-invested companies can also apply to ACAR to maintain records in English and USD, provided formal approval is obtained in advance.

4. Beneficial Ownership and KYC Declarations

• Who must comply: All entities registered with the MOC and GDT are expected to maintain accurate records of beneficial owners (those who ultimately own or control 25% or more of shares, voting rights, or the entity’s decision-making). This is embedded in the ADCE filing process.
• Update frequency: Beneficial ownership information must be updated whenever a change occurs in shareholders, directors, or controlling parties, and confirmed annually through the ADCE filing with MOC.
• KYC at GDT: The GDT cross-references taxpayer identity, ownership, and transactional data through its digital systems. Discrepancies between what your clients report paying you and what you declare can trigger an automatic audit flag.
• Corporate secretary requirement: Per the 2022 amendments to the Law on Commercial Enterprises, all Cambodian LLCs must appoint a locally resident corporate secretary, who plays a key role in maintaining internal governance records.
• Penalties for non-disclosure or inaccurate filings: While Cambodia does not yet operate a fully centralized public beneficial ownership register comparable to the UK or EU models, failure to maintain accurate records and update the MOC can compound penalties during GDT audits or MOC inspections.

5. Payroll, VAT, and Other Periodic Filings

Monthly obligations (due by the 25th of the following month):

• VAT return: Standard rate is 10% on most goods and services. Mandatory registration for businesses with an annual turnover exceeding KHR 125 million (approx. USD 31,250). Monthly e-filing with payment to the GDT.
• Withholding Tax (WHT): Applies to payments made to both residents and non-residents, including rent, royalties, interest, management fees, and services. Filed and paid monthly alongside VAT returns.
• Tax on Salary (ToS): Progressive rates for residents; flat 20% for non-residents on Cambodian-sourced salary income. Monthly e-filing is mandatory.
• Fringe Benefit Tax (FBT): Declared and paid monthly for non-cash benefits provided to employees.

Monthly/bi-monthly labor obligations:

• NSSF contributions: Employers contribute 2.6% of gross monthly salary per employee. Payments are due by the 15th of the following month; reporting is due by the 20th.
• Labor self-inspection: Businesses must submit an online self-declared labor inspection report twice per year, prior to June and December, respectively.

Annual labor filings:

• Foreign employee quota application: Due November 30 each year for the following year’s quota from MLVT. Foreign nationals can make up a maximum of 10% of the total workforce headcount.
• Foreign work permit renewal: Due March 31 each year for all currently employed foreign staff.

Penalties for Late or Inaccurate Filings in Cambodia

• Additional tax penalties: 10% of underpaid tax for voluntary late filing; 25% when the GDT identifies the underpayment during a desk or limited audit; 40% when the GDT issues a unilateral reassessment, typically where the taxpayer fails to cooperate with the audit process.
• Monthly interest: 1.5% per month on underpaid or late-paid tax, accruing from the original due date of the payment. This compounds quickly over several months.
• ACAR penalties: Late or non-submission of financial statements carries a fine of between KHR 800,000 and KHR 2,000,000 (approx. USD 200 to USD 500) per instance.
• MOC penalties: Missing the ADCE deadline triggers a KHR 2,000,000 (approx. USD 500) penalty per year of non-compliance. After three consecutive years without filing, the MOC can revoke your company’s registration entirely.
• Accounting language violations: Operating books in a language other than Khmer without ACAR approval carries fines of up to KHR 800,000.
• Foreign worker violations: Hiring a foreign national without a valid work permit can result in fines of up to KHR 12.6 million (approx. USD 3,150) per worker, and repeated violations can lead to deportation proceedings.
• Loss of Gold Taxpayer status: The GDT issues compliance certificates rated Gold (16-20 points), Silver, and Bronze. Gold status brings real benefits: exemption from routine audits and faster VAT refunds. A pattern of late or inaccurate filings will drop your rating and expose you to more frequent audits.
• Loss of QIP incentives: QIPs that fail to file their Certificate of Compliance with the CDC within 20 days of the TOI filing deadline risk losing their entire tax holiday and duty exemption package.
• Strike-off risk: Persistent non-filing across MOC and GDT channels can result in license suspension, forced closure, or deregistration.

Annual Compliance Cost Breakdown

60-Day Compliance Sprint Checklist

Regulatory and Compliance Obligations

• GDT monthly tax filings: Every registered business must file VAT, withholding tax, and Tax on Salary returns electronically by the 25th of each following month.
• Annual Tax on Income (TOI) return: Self-assessment entities must calculate and submit net taxable profit returns to the GDT by March 31 each calendar year.
• Patent tax renewal: A separate annual business operating fee, also due March 31, ranging from USD 50 for small taxpayers up to USD 1,250 for large taxpayers.
• ADCE filing with MOC: Every company must confirm or update its commercial registration details annually through the CamDX portal within 90 days of its anniversary date.
• ACAR financial statements: Unaudited statements are due April 15; audited statements are due July 15, with mandatory IFRS-aligned accounting standards for medium and large entities.
• NSSF contributions: Employers contribute 2.6% of gross monthly salary per employee, with payments due by the 15th and reporting due by the 20th of the following month.
• MLVT labor filings: Foreign worker quotas must be applied for by November 30 each year, and work permits renewed by March 31 for all current foreign staff.
• QIP Certificate of Compliance: Investment project holders must submit their CDC compliance certificate within 20 days of filing the annual TOI return or risk losing their tax holiday status.
• Transfer pricing local file: Effective January 2025, under Prakas 574, companies with related party transactions must prepare and retain a local transfer pricing file alongside the TOI submission.
• Sector-specific licenses: Businesses in food, healthcare, finance, construction, and hospitality face additional annual renewals through their respective ministries, with deadlines that vary by sector.

Staying across all of this manually, especially across multiple countries, is where most growing businesses start losing ground. At Commenda, we built our platform specifically for this problem, centralizing every obligation into one compliance dashboard. 

We flag your deadlines before they arrive, not after, so your team is always working ahead of the calendar.

Common Mistakes and How to Avoid Them

• Using the wrong fiscal year end: Cambodia defaults to December 31, and changing it requires prior GDT approval before the new financial year begins. Filing on a different calendar without approval creates a mismatch that audit systems flag immediately.
• Submitting financial statements without all director signatures: ACAR submissions must carry certified signatures from every director on your MOC records. One missing signature makes the submission technically incomplete, exposing you to late penalties even if you filed on time.
• Under-reporting income by omitting related party transactions: Prakas 574, fully effective January 2025, requires all intercompany payments to be declared in a local transfer pricing file. Non-disclosure triggers reassessment penalties of 40% of understated tax, plus 1.5% monthly interest.
• Missing beneficial ownership updates after a share transfer: Ownership changes must be reported to the MOC immediately, not held until the next ADCE cycle. Discrepancies between your MOC register and GDT profile can stall banking relationships and tender eligibility.
• Operating books in English without ACAR notification: Cambodia requires accounting records in Khmer by default. Foreign businesses can use English, but must formally notify ACAR within 60 days. Missing this can trigger fines.

How Commenda Simplifies Annual Compliance and Tax Filings

Commenda is a San Francisco-based global compliance platform that helps businesses incorporate, manage entities, and automate tax and regulatory filings across 70 countries from a single dashboard.

• Deadline tracking on autopilot: Commenda’s unified compliance calendar auto-tracks every regulatory obligation across all your entities and jurisdictions, sending smart reminders well in advance so nothing slips through while your team is focused on operations.
• Pre-filled forms that save hours: The platform pre-populates filings using your existing entity data, reducing the manual data entry that causes most errors and cutting the time spent preparing each submission significantly.
• Filings managed across 70 countries: Whether you’re filing a TOI return in Cambodia, a corporate tax return in Singapore, or a VAT declaration in the UAE, Commenda handles the full submission workflow across every jurisdiction your business operates in.
• Up to 80% reduction in admin time: By automating routine compliance tasks, document generation, and deadline management, Commenda frees your finance and legal teams to focus on growth rather than paperwork, with users consistently reporting dramatic reductions in hours spent on compliance each month.

With Commenda, you get a clear view of every obligation your business carries across every country you operate in.

If you’re ready to stop managing compliance manually and start running it on autopilot, book a demo today.