🇰🇭 Cambodia · reviewed 2026-10-09
Tax on royalties and franchise fees in Cambodia
Cambodia withholds 14% from royalties paid abroad, but its treaties with neighbouring countries cut that to 10%. For a Vietnamese franchisor, the Vietnam–Cambodia treaty applies, and it names trademark payments as royalties.
Withholding tax
- A Cambodian resident paying royalties to a non-resident must withhold 14% tax. Secondary · PwC Worldwide Tax Summaries, Cambodia, 2026-04-02
- Cambodia has tax treaties in force with Singapore and Thailand (from 1 January 2018) and Brunei, China and Vietnam (from 1 January 2019). Most reduce withholding tax on royalties to 10%. Secondary · DFDL on Cambodia's tax treaties, 2019-01-08
- Under the Vietnam–Cambodia treaty, signed on 31 March 2018, source-country tax on royalties is capped at 10% of the gross amount, and royalties expressly include payments for the use of trademarks. Official · Vietnam–Cambodia tax treaty text, VCCI WTO Center, 2018-03-31
VAT
- Cambodia charges 10% VAT. When a non-resident without a permanent establishment supplies services, the Cambodian customer accounts for the VAT under reverse charge. Secondary · Chambers Investing In 2026: Cambodia, 2026-01-20
Planning points
- Collect a certificate of tax residence from your home tax authority before the first payment if you rely on a treaty rate.
- State in the agreement whether royalties are gross or net of withholding tax.
- Remind the franchisee that it, not you, accounts for the 10% VAT on your fees.
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