The General Department of Taxation issued notification no. 3830 on January 24, 2024, establishing the market annual interest rate for KHR at 9.66% and USD at 8.75% in 2023. These rates are applicable in the following circumstances:

1. Employee loans made by the employer for the purpose of computing discretionary benefit tax.
2. Lending among affiliated entities

Nevertheless, taxpayers are granted the alternative of following Instruction No. 10979, dated August 25, 2022, should they wish to forgo the application of the arms' length interest rate. The submission of the following documents is required per this instruction:

• A complete loan agreement.
• The purpose of the loan should be detailed in either a business plan or projected financial statements.
• A resolution of the board of directors, which is required for limited liability companies and non-sole proprietorships.