Issued: 31 December 2025
The Ministry of Economy and Finance (MEF) has issued Circular No. 024, dated 31 December 2025, providing important clarification on the withholding tax (WHT) exemption applicable to royalty and interest payments made between taxpayers under the self‑assessment regime.
This Circular aims to streamline compliance, reduce administrative burdens, and further support Cambodia’s business environment by simplifying tax procedures for self‑assessment taxpayers.
Key Points of Circular 024
1. WHT Exemption on Royalties and Interest
All royalty and interest payments made between taxpayers under the same self‑assessment regime are exempt from withholding tax.
2. Income Must Still Be Declared by the Recipient
Although WHT is exempt, enterprises under the self‑assessment regime receiving the royalty or interest income must record it as taxable income and declare Tax on Income in accordance with applicable tax laws and regulations.
3. Valid Tax Invoices Required
The WHT exemption applies only when the payment is supported with a valid and proper invoice issued by the self‑assessment taxpayer
Invoices must comply with invoice requirements and existing provisions. Without proper invoicing, the exemption is not applicable.
Effective date of Implementation: From date of Signing 31 December 2025
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.
DFDL provides specialized Tax & Transfer Pricing counsel throughout the ASEAN region. Visit our Cambodia team office for more information.
