On January 20, 2026, the General Department of Taxation (“GDT”) issued Notification No. 2158 GDT, establishing the market interest rates for 2025 at 9.36% per annum for Khmer Riels and 8.45% per annum for US Dollars. Derived from the average rates of 12 major domestic commercial banks, these rates represent a notable shift in tax administration policy, as the notification explicitly restricts their application to fringe benefit tax purposes only.

Policy Reversals The scope of the GDT’s annual interest rate notifications has fluctuated significantly over the past decade:

• 2014–2018: A single rate was applied uniformly to both employee loans and related-party loans.
• 2019: The scope was narrowed to employee loans only, requiring related-party loans to be justified under transfer pricing rules.
• 2022–2023: The policy reversed, applying the rates to both employee and related-party loans.
• 2024: The scope shifted again to cover related-party loans exclusively.
• 2025: The GDT has reverted to the 2019 stance, limiting the rates to employee loans for fringe benefit tax calculations.

Implications for Taxpayers With the published rates no longer serving as a benchmark for related-party financing, inter-company loans fall back under the transfer pricing regime. This history of regulatory oscillation underscores the unpredictability of administrative practices in this area. Consequently, taxpayers engaged in related-party financing should prioritize maintaining robust  documentation to substantiate their interest rates in anticipation of future audits.