On 4 August 2026, the Ministry of Economy and Finance (“MEF”) issued Notice No. 008 on the Principles of Exemptions and Tax Concessions on the Transfer of Ownership or Possession of Immovable Property (“Notice 008“). Notice 008 introduces a package of tax relief and concessions granted by the Royal Government to support property owners, facilitate the regularization of property ownership, and encourage the timely completion of land registration and title transfer procedures.
Key Highlights
- Suspension of the additional tax for late payment of stamp duty equal to 100% of the stamp duty payable, applicable to accompanying notices or transmittal letters exceeding three months from the date of issuance by the Municipal-Provincial Department of Land Management, Urban Planning, Construction and Cadastre, until the end of 2027.
- Extension of the one-time stamp duty relief under Notice No. 367 dated 2 May 2017 (issued by the Council of Ministers), allowing stamp duty to be paid only on the final transfer where immovable property has a history of multiple successive possession transfers.
- Simplified documentation for stamp duty and immovable property tax on completed buildings, which may be determined on the basis of a construction permit or a certification of the construction date issued by the relevant competent authorities.
- Stamp duty exemption on the transfer of ownership or possession of immovable property where the owners are military personnel and national police participating in front-line battlefields, subject to certification of identification and duty roles by their respective units.
DFDL Comments
Notice 008 is a welcome development for property owners who have not yet completed their land registration or title transfer procedures, offering a meaningful opportunity to regularize ownership at a significantly reduced cost. In particular, the suspension of the 100% additional tax penalty for late stamp duty payments, the continued availability of the one-time stamp duty treatment for properties with multiple historical transfers, and the simplified documentation requirements for certain property tax obligations should translate into material tax savings and a reduced administrative burden for affected taxpayers.
Taxpayers should note, however, that Notice 008 has no retroactive effect on taxes, including administrative penalties (additional tax and interest), that have already been paid. Property owners with files currently pending at the Municipal-Provincial Department of Land Management, Urban Planning, Construction and Cadastre or at the tax administration are encouraged to complete the relevant procedures promptly in order to benefit from these measures.
Tax services required to be undertaken by a licensed tax agent in Cambodia are provided by Mekong Tax Services Co., Ltd, a member of DFDL and licensed as a Cambodian tax agent under license number – TA201701018.
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