Cambodia Transfer Pricing Documentation Requirements
Cambodia's transfer pricing documentation regime under Prakas 574 applies from 1 January 2025, requiring documentation from taxpayers with related-party transactions unless a small-taxpayer exemption is met. A related-party disclosure annex is filed with the corporate income tax return.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Prakas 574
Required | Taxpayers with related-party transactions; exempt below ~KHR 8bn turnover and ~KHR 4bn assets | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. | EN | Yes (obstruction penalty; reassessment where unsupported) |
Disclosure annex Annex 1
Annual filing | Taxpayers with related-party transactions | With the CIT return (within 90 days of year-end) | Submission deadline The documentation must be filed with the tax authority by the date shown. | EN | Yes |
Calculate your exact Cambodia deadline
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Scope of the documentation obligation
Under the transfer pricing regulations in Prakas 574, effective from 1 January 2025, a taxpayer with related-party transactions must prepare documentation unless it qualifies for the small-taxpayer exemption. That exemption applies where, during the year, the taxpayer has annual turnover of less than approximately KHR 8 billion and tangible assets of less than approximately KHR 4 billion, together with the related condition on its transactions. A related-party disclosure annex is filed with the corporate income tax return, which is due within 90 days of the fiscal year-end.
Distinctive features of the Cambodian regime
The defining feature of the Cambodian regime is its recency: the documentation framework under Prakas 574 applies only from 2025, so it represents a newly formalised obligation rather than a long-standing one, structured around a small-taxpayer safe harbour defined by turnover and assets. The enforcement runs through the audit rather than a fixed documentation fine. Where no documentation is available it is difficult to justify the pricing of related-party transactions, exposing the taxpayer to a transfer pricing adjustment, and an obstruction penalty can apply where requested documents are not submitted. There is no Country-by-Country reporting obligation in the regime as captured.
Benchmarking and comparables
Local comparables are preferred, but they are difficult to find given the limited publicly available data and the small number of locally listed companies, so regional comparables are accepted. There is no stated preference between single-year and multi-year testing, and a roll-forward study is acceptable. The general limitation period is three years, extendable to ten years where fraud or obstruction is involved, with audits generally covering the previous three unaudited years.
Frequently asked questions
When did Cambodia's transfer pricing documentation regime take effect?
The framework under Prakas 574 applies from 1 January 2025, with a small-taxpayer exemption defined by turnover of less than around KHR 8 billion and assets of less than around KHR 4 billion.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.