Tax & Transfer Pricing Archives

The General Department of Taxation (“GDT“) has postponed the application of Capital Gains Tax (“CGT“) under Prakas No. 496 MEF dated 18 July 2025, by issuing Notification No. 34236 on 30 October 2025.

The purpose of the Notification is to notify all taxpayers of the postponement of the implementation of CGT as outlined in Prakas No. 496 MEF on the six categories of capital assets that are subject to CGT obligations, particularly immovable property, leases, investment property, goodwill, intellectual property, and foreign currency. The new implementation date of the CGT for all types of capital is from 1 January 2026.

For additional details regarding Prakas. No. 496 on Capital Gains Tax, please visit our website at: https://www.dfdl.com/insights/legal-and-tax-updates/realizing-gains-facing-tax-cambodia-finalizes-capital-gains-tax-regime/.Realizing Gains, Facing Tax: Cambodia Finalizes Capital Gains Tax Regime – DFDL

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.

On 9 October 2025 the General Department of Taxation (“GDT”) issued Notification no. 32322 extending the deadline for Tax on Immovable Property (TOIP) payment for 2025 to 31 December 2025 (Previously 30 September 2025).

The extension aims to accommodate property owners who have not yet registered or paid their TOIP. In addition, the Royal Government continues to waive administrative fines (additional tax and interest) under certain conditions to encourage compliance:

Properties that are not registered: Owners of properties that have never been registered or declared can register and declare starting from the year they first possessed or benefited from the property.

Previously Registered Properties: Owners who missed declarations in prior years are exempt from administrative penalties until the end of 2025 (But penalties already paid will not be refunded).

In the meanwhile, property owners who have not registered for TOIP must update their property information or register at the provincial or district tax branch. Payment can then be completed by 31 December 2025 through various channels, including GDT offices, authorized banks, or the GDT Taxpayer App.

The National Board of Revenue (NBR) has officially released the authentic English text of the Income Tax Act, 2023 through a gazette notification dated 8 October 2025.

Originally enacted in Bangla, the Income Tax Act, 2023 replaced the previous Income Tax Ordinance, 1984 in June 2023, marking a major shift in Bangladesh’s direct tax regime. Since its enactment, stakeholders, particularly foreign investors and multinational entities, have been requesting an official English version to ensure uniform interpretation, consistency, and ease of application in cross-border tax and compliance matters.

The publication of the English text comes after more than two years of translation, review, and vetting by the NBR and the Legislative and Parliamentary Affairs Division, aiming to provide an authoritative reference for both domestic and international users of the law.

The newly published English text incorporates all legislative amendments made up to the Finance Act, 2024. However, it does not include the subsequent changes introduced by the Finance Act, 2025.

For a copy of the Gazette, please click the download button below.

On 11 September 2025, the Ministry of Finance and Revenue of Myanmar issued Notification No. 107/2025 (“Notification 107”) introducing the Customs Rules on Copyrights and Related Rights. These rules establish a formal framework for recording intellectual property rights with the Customs Department and provide enforcement mechanisms to prevent the importation of infringing goods. The new procedures aim to enhance border protection of intellectual property and align Myanmar’s customs practices with international standards.

Outlined below are the key provisions introduced under Notification 107.

Applicants (or right holders) may now formally record their copyrights or related rights with the Customs Department by submitting a completed Form (1) to the Director-General. Upon receipt, the Customs Department will assess the application and, if complete, will register the records and notify the applicant using Form (2) within 15 days. If the application is incomplete, the applicant will be notified and given 7 days to provide the missing information. Should the applicant fail to submit complete information within the specified timeframe, the application will be rejected via Form (3).

Once accepted, the records remain valid for two years. Applicants may renew the records for an additional two-year term by submitting Form (4) at least 30 days before the current validity expires. Any amendments or withdrawals of previously recorded information must be reported to the Customs Department within five days of the change. If the Customs Department finds that the applicant has violated any provisions of the Copyright Law or related regulations, the recordation may be cancelled.

2. Suspension Orders Against Infringing Imports

Applicants who possess credible evidence or reasonable grounds to suspect that infringing goods are being imported into Myanmar may request a suspension order by submitting Form (5) to the Director-General. This application can be made regardless of whether the goods have been previously recorded with the Customs Department. For unrecorded goods, the applicant must also provide supporting documents, including proof of ownership or legal importation of the copyright or related right, evidence of infringement, and any other relevant materials.

Applications may be submitted in person, electronically, or by mail, and must be prepared in either Myanmar or English. If requested, a certified translation must be provided. The Customs Department will review the application and notify the applicant of acceptance using Form (6) within 30 days. If the application is incomplete, the applicant will be given 15 days to submit the missing information. Failure to do so will result in rejection via Form (7). Once accepted, the applicant must pay a security deposit within 7 days; otherwise, the application will be rejected.

3. Customs-Initiated Suspension Orders

In addition to applicant-initiated actions, the Customs Department may independently issue a suspension order if it finds credible evidence or reasonable suspicion that goods infringe copyrights or related rights. In such cases, the Department will notify both the right holder and the importer using Form (8). The right holder must then pay the required security deposit within 15 days to maintain the suspension. If the deposit is not paid, the suspension order will be cancelled, and the goods will be released to the importer with restrictions prohibiting public distribution or sale.

4. Appeals and Legal Proceedings

Importers who disagree with a suspension order may appeal to the Intellectual Property Court within 15 days of receiving the notification. The Customs Department is required to act in accordance with the Court’s decision. During the suspension period, both the applicant and the importer may inspect the goods simultaneously to verify infringement. The applicant must report the status of legal proceedings within 3 days for perishable goods and within 15 days for other goods. If necessary, the suspension period may be extended by up to 15 days. Failure to report within the prescribed period will result in cancellation of the suspension order and release of the goods.

5. Costs and Security Deposit Management

If the Intellectual Property Court confirms that the suspended goods infringe copyrights or related rights, the importer must pay the costs associated with storage, destruction, or removal of the goods within 30 days. Upon payment, the Customs Department will return the applicant’s security deposit. If the importer fails to pay, the Customs Department may initiate legal proceedings to recover the costs. Any remaining portion of the deposit will be refunded to the applicant once expenses are recovered.

However, if the Court finds no infringement, the applicant must compensate the importer for any damages resulting from the wrongful suspension. Proof of compensation must be submitted to the Customs Department before the security deposit is refunded.

6. Exemptions

Certain categories of goods are exempt from these rules, including transshipment cargo, reshipment cargo, retention cargo, and transit cargo. In addition, goods permitted by the State for public interest purposes are not subject to these provisions.

Conclusion

Notification 107 introduces a comprehensive framework for the protection of copyrights and related rights at Myanmar’s borders. By formalizing procedures for recording and enforcement, the Customs Department enhances its capacity to prevent the importation of infringing goods. Businesses involved in the import or export of copyrighted materials should familiarize themselves with these new rules and ensure compliance to avoid potential disruptions and liabilities.

The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.

Unlock the latest insights and stay ahead in Cambodia’s fast-evolving trade landscape with the newly released DFDL Cambodia Customs Guide 2026 — your essential resource for navigating customs regulations and compliance.

Authored by DFDL experts Clint O’Connell (DFDL Cambodia’s Managing Director and Head of Cambodia Tax and Customs Practice), Diberjohn Balinas (Cambodia Tax Partner), and Kosal Dun (Senior Manager of Cambodia Customs and Compliance Practice), the guide offers practical insights for customs professionals, import/export businesses, legal advisors, and investors. It covers key procedures, duties, taxes, and trade agreements, designed to help businesses stay compliant and competitive.

Highlights include:

Clear guidance on import, export, and transit procedures
In-depth coverage of Best Traders and AEO programs
Updates on major trade agreements (RCEP, CAM-UAE CEPA)
Impact of U.S. tariffs on Cambodian trade
Latest GDCE updates on customs transit and bonded warehouses
New GDCE customization procedures

Equip yourself and your business with the most up-to-date and comprehensive customs resource available. Visit the DFDL website to read more or download your copy of the Cambodia Customs Guide 2026 today and ensure you are prepared for the challenges and opportunities ahead.

Join us for the Taxand Asia Pacific Regional Tax Conference on 20 November 2025, in Bangkok, Thailand. This full-day event will gather leading tax experts from various countries, including Thailand, Vietnam, Singapore, India, Mauritius, the Philippines, Indonesia, China, and the United States, to share invaluable insights and effective strategies.

Highlights include:

Planning for mergers and acquisitions (M&A) in Asia
Transfer pricing strategies for multinational companies
Tax-efficient structuring for cross-border investments
Navigating U.S. tariffs
Individual tax planning in Asia
Compliance with the OECD’s global minimum tax

Details:

Date: 20 November 2025
Venue: Le Meridien Bangkok, Thailand
Who should attend? CFOs, Financial controllers, Tax Managers, and C-levels.

Reserve your spot now

Get the agenda by clicking the green download button.

On 25 August 2025, the Ministry of Economy and Finance issued Prakas 671, which introduces updated procedures for licensing and operating Customs Bonded Warehouses in Cambodia. This new Prakas repeals the earlier Prakas 116 dated 15 February 2008, reflecting the government’s efforts to modernize customs administration, improve compliance, and align with international best practices.

Continuity in Core Principles

Prakas 671 builds on the foundational framework established by Prakas 116, maintaining consistency in the regulation of customs bonded warehouses. Both regulations classify warehouses into three types — Type A (Public), Type B (Private), and Type C (Special) — and uphold the principle of suspending duties and taxes on goods stored under customs control. They also reinforce the responsibilities of warehouse operators to maintain secure facilities, provide adequate space for customs officers, and ensure comprehensive recordkeeping and traceability of goods.

Key Changes and Comparison

The table below summarizes the major differences between the repealed Prakas 116 and the newly issued Prakas 671 (which took effect on 25 August 2025) focusing on license fees, security deposit, and storage requirements:

	Under Prakas 116	Prakas 671 (effective 25 August 2025)
License Fee	1% of average monthly duties and taxes outstanding; no minimum specified	Higher of KHR 2 million or 1% of average monthly duties and taxes outstanding
Security Deposit	5% of annual duties and taxes outstanding; amount adjustable by the General Department of Customs and Excise (“GDCE”)	Fixed cash deposit of KHR 300 million
Storage Duration	Up to 2 years, with possible 12-month extension	Up to 180 days, with possible 180-day extension depending on goods’ condition and GDCE’s assessment

Prakas 671 introduces stricter financial and operational requirements for customs bonded warehouse operators. The introduction of a fixed security deposit and a minimum license fee standardizes financial obligations, while the reduction in storage duration reflects a shift toward greater inventory turnover and tighter customs control.

Businesses operating customs bonded warehouses or engaged in import-export activities are encouraged to assess their current operations and compliance procedures to ensure alignment with the new regulatory framework. If assistance is needed, DFDL stands ready to support with license applications, regulatory compliance reviews, and strategic planning.

The Ministry of Economy and Finance (MEF) has issued Prakas 648 MEF.PrK.GDT dated 12 August 2025 (“Prakas 648”), providing comprehensive rules on Tax on Income (ToI), Special Tax, and Value-Added Tax (VAT) for enterprises engaged in transporting passengers and/or cargo by air.

This new regulation expands upon the earlier Prakas 198 (17 March 2025), which introduced the foundation for airline taxation in Cambodia. Together, these measures provide greater clarity, certainty, and predictability for both resident and non-resident operators in the aviation sector.

Click “Download” to read Tax Obligations for Airway Transport Businesses

To support the growing adoption of electric vehicles (“EVs”) in Cambodia and align with the National Policy on Electric Vehicle Development, the Ministry of Economy and Finance (“MEF”) issued Notification 009 on 21 August 2025, amending the Tax on Means of Transportation applicable to EVs. The changes revise tax rates for specific vehicle categories under Prakas 738, which governs annual tax obligations for various types of transportation means.

Key Change

The revised tax rates apply to EVs based on horsepower and manufacturing year, as outlined below. The amendment only affects categories C to E. Categories A and B remain unchanged.

No.	Horsepower	Manufacturing Year
No.	Horsepower	5 years (in Riels)	More than 5 years to 10 years (in Riels)	More than 10 years (in Riels)
A	Up to 150 horsepower	100,000	80,000	60,000
B	More than 150 to 200 horsepower	150,000	100,000	80,000
C	More than 200 to 250 horsepower	300,000	150,000	100,000
D	More than 250 to 300 horsepower	500,000	250,000	150,000
E	More than 300 horsepower	800,000	400,000	200,000

While Notification 009 does not specify an effective date, we understand that the changes are effective from the date of issuance (i.e., 21 August 2025). This interpretation aligns with the annual tax payment deadline for the Tax on Means of Transportation, which is 30 November 2025.

For further details on the Tax on Means of Transportation, including Prakas 738, you may refer to our previous alert here: Cambodia: Updated Tax on Transportation Means for 2025 – DFDL

This comprehensive guide offers practical insights into Bangladesh’s tax system, recent developments, and their implications for businesses across various sectors. Whether you’re a foreign investor, local entrepreneur, or tax professional, this resource provides valuable information to navigate the tax landscape effectively.

The 2025 Bangladesh Tax Guide covers:

The legal framework and administration of taxation in Bangladesh
Types and rates of taxes for different entities and transactions
Tax incentives and exemptions for specific activities and industries

Download your complimentary copy of the 2025 Bangladesh Tax Guide by clicking the button below:

As Cambodia’s capital gains tax (CGT) regime continues to evolve, the General Department of Taxation (GDT) issued Instruction 23862 dated 4 August 2025 on the Implementation of Capital Gains Tax under the Framework of Double Taxation Agreements (DTAs). This follows the enactment of Prakas No. 496 MEF.P, dated 18 July 2025 – click here for more information, and builds upon existing DTA implementation guidance from Instruction No. 4084 GDT (2018).

Instruction 23862 clarifies how Cambodia will apply CGT rules where a DTA is in force, and how taxpayers may access relief or exemption from CGT under such agreements.

Click “Download” to read Capital Gains Tax Implementation – Double Taxation Agreements: New Instruction Issued

The Ministry of Commerce (“MOC”) and Customs Department have recently issued several important updates affecting exporters, importers, and intellectual property stakeholders. These developments cover extension of export licensing procedures for certain commodities, new registration procedures and deadlines under the Tradenet 2.0 system, the opening of applications for Collective Management Organizations, and updated customs clearance service hours.

This alert provides a summary of these important changes to help businesses stay informed and compliant.

1. Export Licensing Update for 97 Commodities

On 11 July 2025, the MOC issued Export and Import Newsletter 3/2025, confirming the continued application of the Automatic Licensing system for the export of 97 commodity lines (identified by 10-digit HS Codes) via sea routes. This measure, initially introduced on 15 June 2025 to support export operations following the earthquake, will remain in effect until 31 August 2025.

However, for border trade routes, these 97 commodities must be exported under the Non-Automatic Licensing system, in accordance with the earlier Export-Import Newsletter 2/2025.

2. Exporter/Importer Registration Fee Deadline under Tradenet 2.0

On 17 July 2025, the MOC issued Export and Import Newsletter 4/2025, announcing updated procedures for exporters/importers and related registrations under the Tradenet 2.0 system, effective 1 August 2025. The important updates under this Newsletter are as follows:

Registration types include, but are not limited to, Exporter/Importer Registration, Business Agent Registration, Sales Center and Showroom Licenses for vehicle and machinery imports, EV and alcohol sales, Duty-Free Shop Registration, and Online Sales Business Registration.
Applicants must pay the registration fee within 21 days from the Trade Department’s approval date.
Late payments will incur penalties:
- MMK 100,000 (Day 22–30)
- MMK 200,000 (Day 31–60)
- MMK 300,000 (Day 61–90)
After 90 days, the system will automatically cancel the application.
Non-compliance may result in a 1-year ban on new applications and a temporary suspension of existing exporter/importer registration.

3. Applications Open for Establishing Collective Management Organizations (CMOs)

On 16 July 2025, the Intellectual Property Department under the MOC issued Announcement No. 1/2025, officially opening the application process for the establishment of CMOs in accordance with the Copyright Law and related regulations.

Application Methods: Applications for establishing a CMO may be submitted either in person at the relevant government office or online through the designated copyright system. Online applicants must register and log in using a Gmail account. User guides and application instructions are available on the system.

Required Form and Documents: Applicants must complete the Form CMO-1 and submit it along with supporting documents, including organizational details, royalty-related criteria, and relevant agreements.

Application Fee: The application fee of MMK 800,000 can be paid via POS using MPU cards or CB Pay for in-person submissions. For electronic applications, payment is accepted through CB Bank or AYA Bank.

This marks an essential step in enabling creators and rights-holders to manage and enforce their copyright and related rights collectively.

4. Customs Clearance Service Hours Update

On 16 July 2025, the Customs Department issued a letter addressed to the Union of Myanmar Federation of Chambers of Commerce and Industry, requesting that the information be shared with relevant companies regarding Customs Clearance service hours. The aim is to facilitate the smooth and expedited flow of goods.

According to the letter, the Customs Department has been providing 24-hour service with three shifts for Customs Clearance at Asia World Port Terminal (AWPT) since 20 March 2024. Additionally, Customs Clearance services are available at other international ports from 9:00 AM to 6:00 PM.

Conclusion

These recent updates from the MOC and the Customs Department reflect the government’s ongoing efforts to streamline trade procedures, enhance compliance, and support economic recovery. Exporters, importers, and IP stakeholders are encouraged to review these changes carefully and ensure timely compliance to avoid penalties or disruptions. Should you require further clarification or assistance in navigating these new requirements, our team is ready to support you.

Cambodia is turning the page on the taxation of capital gains. In a bold move to align with global tax practices and strengthen fiscal equity, the Ministry of Economy and Finance has officially implemented Cambodia’s Capital Gains Tax (CGT) regime.

The Cambodian Government has introduced Prakas 496 MEF.PRK on Capital Gains Tax dated 18 July 2025 (“Prakas 496”). Prakas 496 signals a clear message: gains from property, shares, and financial assets are no longer out of the tax authority’s reach from their respective dates of implementation.

Whether you’re a real estate investor, shareholder in a Cambodian company, or considering a group restructure that involves Cambodian companies, the new CGT framework brings a mix of structure, scrutiny, and strategic opportunity.

With a flat 20% tax rate and detailed exemptions, deductions, and filing procedures, understanding Prakas 496 is not optional—it’s essential.

The rollout of CGT begins from 1 September 2025 for leases, investment property (which includes shares), business goodwill, intellectual property, and foreign currency, with real estate coming under the spotlight from 1 January 2026. That gives stakeholders a narrow window to reassess their portfolios and prepare for compliance.

We summarize below the key points of Prakas 496 with a more detailed analysis of some of the more critical aspects concerning share transfers.

Click “Download” to read Cambodia Finalizes Capital Gains Tax Regime.

On June 17, 2025, the Vietnam National Assembly passed Resolution 204/2025/QH15, extending the 2% VAT rate reduction. Following this, on 30 June 2025, the Government of Vietnam issued Decree 174/2025/ND-CP, which provides implementation guidance for the VAT reduction.

The reduced 2% VAT rate will be in effect from 1 July 2025 until 31 December 2026.

In comparison to the previous VAT reduction that applied until 30 June 2025, Resolution 204/2025/QH15 includes some adjustments to the scope of the extended 2% VAT reduction. Notably, the sectors now eligible for the reduced rate include transportation services, logistics, and information technology goods and services. However, certain sectors that were originally VAT-exempt have been excluded from this reduction, specifically education, vocational training, medical services, finance, banking, securities, and insurance. Additionally, sectors such as telecommunications and real estate, which have seen recent growth, are also not eligible for the VAT reduction.