General Department of Taxation (GDT) issued Prakas 542 MEF.P on the Rules and Procedure for the Implementation of VAT on E-Commerce (“Prakas 542”) on 8th of September 2021.

Who is affected?

Taxable Person is as followed:

1. Non-Resident Taxpayers who supply of digital goods or digital service or for all e-commerce activities into Cambodia and must be obligation to VAT registration as stated in article 11.
2. Self-declared taxpayer who receives supplies of digital goods or digital service or all E-commerce activities from Non-resident taxpayers.

Non-Resident Taxpayers who supply digital goods or digital services or all e-commerce activities to Cambodia have an annual turnover of 250 million Riels or expected to have turnover for three consecutive months completed in the current calendar year of 60 million Riels, it is obliged to complete the Simplified VAT registration within 30 days after the turnover is due to register.

Completion of the VAT registration application is defined in Khmer or English by doing the following:

1. E-registration through the website https;//www.tax.gov.kh in the form and information defined by the Tax administration or submit directly with the Tax administration.
2. For E-registration or direct registration with the tax administration, non-resident taxpayers can choose to use the Tax agency to facilitate registration in Cambodia.
3. Requirement documents as following:

- Application form of VAT registration

- Non-Resident Taxpayers certificate

- Identity Card or Passport of the owner or Representative

- 2 sheets of Photo of Director or Representative no later than 3 months, size 35× 45mm with white background

- Certificate of Bank Account information of Non-Resident Taxpayers issued by or printed out of the Non-resident taxpayer banking system

Non-Resident Taxpayers shall be under Department of Large Taxpayers.

Taxable value

Taxable value if defined as following:

1. Taxable value of supply is a price of digital goods or digital service which seller received from buyer.
2. In case that payment for a taxable supply is a compensation other than cash for the direct or indirect benefit to suppliers, that compensation shall be included in the taxable value as market price.
3. If the taxable value of the digital goods or digital services supplied does not represent the real price, the tax administration may determine a price, and that price shall be deemed valid until there are proof that approved by the tax administration.

Supply Time

VAT shall due and payment when supply. Supply time shall be defined as following:

1. For Non-Resident taxpayers, the time of supply is the first of the time when the invoice is issued or when the digital goods are delivered or the digital service is completed or the payment is received.
2. For Self-assessment taxpayers who receive supply of digital goods or digital service or all E-commerce activities, shall be the reverse charge of the non-resident supplier the time of supply is the first of the time when the digital goods are delivered, or the digital service is completed, or the payment is due or paid.

Tax rate

VAT is defined at the rate of 10% of the VAT on the supply of digital goods or digital services or any e-commerce activities.

Tax Invoice

Non-Resident Taxpayers shall issue invoice and collect tax money from all consumers. Invoice at least shall have information as following:

1. a) Name, Address and TIN of Non-Resident Taxpayers
2. b) Name, Address and/or TIN of Client
3. c) Invoice number and invoicing date
4. d) Detail of digital products or digital which supplied
5. e) Taxable Value and VAT or Total price of supplied included with Tax.

Self-declared taxpayer who receives a taxable supply of digital goods or digital services or any e-commerce activities, shall be tax reverse of the non-resident supplier, whether or not the non-resident supplier VAT registered and shall VAT payment declaration base on the invoice of the non-resident supplier with supporting documents for the purchase and payment.