Representatives of the governments of Cambodia and Singapore on 20 May 2016 signed an agreement for the avoidance of double taxation. This is the first income tax treaty signed by Cambodia.
The treaty is pending ratification by Cambodia and Singapore.
The income tax treaty between Cambodia and Singapore includes withholding tax rates for payments of dividends (a treaty rate of 10%), interest (0% or 10%), royalties (10%), and fees for technical services (10%). The treaty is silent as to the treatment of branch profits taxation.
The Cambodia-Singapore income tax treaty includes rules for determining a permanent establishment, when an entity:
It is implied that entities that do not satisfy these requirements will not have a PE in Cambodia.
The treaty clarifies that income from immovable property in Cambodia will be taxed in Cambodia (and vice versa for property in Singapore). There are other provisions in the treaty concerning the tax treatment of international transport, capital gains, independent personal services, dependent personal services, methods for the elimination of double taxation, and rules for the exchange of tax information.
Read a June 2016 report [PDF 87 KB] prepared by the KPMG member firm in Cambodia: Singapore / Cambodia Agreement for the Avoidance of Double Taxation
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