Cambodia’s new Transfer Pricing procedures for 2025
August 11, 2025
Kreston Cambodia has written a summary of the key takeaways of Cambodia’s new Transfer Pricing procedures for 2025.
The Cambodian General Department of Taxation (GDT) has introduced updated transfer pricing (TP) rules through Prakas 574, dated 19 September 2024, to take effect in 2025. The new framework aligns more closely with OECD guidelines and expands the definition of a “related party” to include any entity that directly or indirectly controls, is controlled by, or is under common control with the taxpayer. This includes the relationship between a permanent establishment and its non-resident parent.
“Control” is defined as holding at least 20% of equity interest or voting rights in a company’s board of directors. However, the GDT retains discretion to determine control based on the facts of each case.
The rules mandate that all Cambodian entities engaging in related-party transactions prepare and maintain Local File TP documentation annually. Transactions covered include loans, sales and purchases of goods, leases, royalties, transfers of intangible assets, and technical or management service fees.
Cambodia’s approach adopts the arm’s length principle and recognises OECD-standard TP methods such as Comparable Uncontrolled Price (CUP), Resale Price Method (RPM), and Transactional Net Margin Method (TNMM). While there is no Mutual Agreement Procedure (MAP) in place, disputes can be addressed through the GDT’s local audit mechanism.
Kreston Cambodia’s TP team supports businesses with compliance, including preparing Local File documentation and benchmarking studies; audit defence strategies; audit support leveraging local and international expertise; strategic planning to optimise supply chains and related-party transactions; and tailored advisory services to ensure both compliance and tax efficiency.
Kreston Cambodia is part of the global Kreston network, providing audit, tax, accounting, and advisory services in Phnom Penh and beyond.
For more information, contact Kreston Cambodia at www.krestoncambodia.com.
