Fiscalité au Cambodge en 2026

This video provides an overview of Cambodia's current tax system, focusing on income tax, different income types, and implications for individuals and businesses, particularly those with French or US connections. A significant point highlighted is the absence of tax treaties between Cambodia and France, and Cambodia and the United States. This lack of treaties increases the risk of double taxation, meaning individuals might be considered tax residents in both their home country and Cambodia, leading to taxation in both jurisdictions. To mitigate this, the strategy is to invalidate tax residency criteria in one country while validating them in the other. The video details Cambodia's tax residency criteria, which are multi-faceted and differ from systems relying solely on the number of days spent in a country, like Thailand. The Cambodian criteria include: 1. **Physical Presence:** Spending more than 182 days within a 12-month period. This period can be a calendar year or a rolling 12-month period, and any fraction of a day counts as a full day. 2. **Residence (Permanent Home):** If one's usual residence or home is in Cambodia, even if not physically present for the majority of the year, Cambodia may consider them a tax resident. This applies to individuals who own or rent property long-term and have personal ties indicating Cambodia as their main base. 3. **Center of Economic Interest:** Similar to French law, this criterion examines economic ties, the location of major assets, active bank accounts, sources of professional or real estate income, and personal ties such as where family resides and where most social time is spent. Crucially, meeting *any one* of these criteria is sufficient for Cambodia to classify someone as a tax resident. However, as stated, this doesn't prevent another country, like France, from also claiming tax residency due to the absence of a tax treaty. Cambodia's tax system taxes **worldwide income**, unlike territorial systems found in countries like Thailand or Singapore. This means all global salaries, capital income, and capital gains are subject to Cambodian tax if one is a tax resident. A notable relief is that Cambodia does not require the declaration of foreign bank accounts, unlike countries such as Indonesia. Instead, Cambodia operates a unilateral tax credit system. If foreign taxes are paid (e.g., withholding tax on dividends), these can be deducted from the Cambodian tax liability. For French tax residents aiming to establish Cambodian tax residency, they must invalidate all French tax residency rules. These French rules include the 183-day rule, the main professional activity, and the center of economic interests. The video mentions a free "economic center of interest calculator" to help individuals assess their situation. Cambodia operates under a **self-declaration system** for taxes, similar to France. Individuals are responsible for accurately declaring their income. The tax brackets in Cambodia are described as not catastrophic, ranging from 0% to 20%. The 20% rate is reached relatively quickly, with incomes from around $3,000 per month being taxed at this top rate. The video specifically addresses the taxation of **dividends** from US equity ETFs. Since there is no tax treaty between Cambodia and the US, the US withholding tax on dividends is 30%. This is significantly higher than the 15% withholding tax applicable in countries like Indonesia or Thailand, which have tax treaties with the US. Consequently, it's advised to favor European-domiciled or US-domiciled accumulating ETFs rather than distributing US ETFs to avoid immediate taxation and the higher withholding tax. Accumulating ETFs reinvest dividends, deferring capital gains tax until the ETF is sold, potentially when the individual is no longer a Cambodian tax resident. To file a tax return in Cambodia, a **Tax Identification Number (TIN)** is required. This can be obtained through the GDT (General Department of Taxation) e-filing portal or a mobile app, with required documents including a passport copy, relevant visa, proof of residence in Cambodia, and a passport photo. A significant portion of the video is dedicated to **US LLCs**. Cambodia does not natively recognize the US concept of a "pass-through entity" for foreign companies. Therefore, all income received by a US LLC is considered by Cambodia as income held by the LLC, not yet distributed to its members. As long as the money remains within the LLC, it is not taxed as personal income in Cambodia. An alternative strategy discussed for US LLC owners to manage worldwide income tax is to take out a **loan** from their US LLC. This borrowed money may not always be considered income, as it's a loan that needs to be repaid. However, this must be done correctly, with a clear loan contract specifying repayment dates and a consistent interest rate (around 3-5%). There's a risk of reclassification if the loan isn't genuinely repaid. The video concludes by inviting viewers to share comments, clarifications, and join a Telegram group for expatriation issues in Southeast Asia. It also mentions the possibility of booking coaching sessions for more specific advice.