Cambodian tax law provides a withholding tax
("WHT") system for many types of income
including services, rent, interest, royalties and dividends. The
applicable rate depends on whether the recipient of the income is a
resident or not. In this article, the WHT regime of Cambodia is
examined with particular attention for those situations which
create the most practical difficulties.
There are widespread misunderstandings about WHT because many
fail to recognize that WHT is just a collection system of tax due
by the beneficiary of the service income, and not tax owed by the
payer of the income. The payer ("withholding agent")
remits the WHT directly to the Tax Department but it is in fact
paid on behalf of the beneficiary of the income. The beneficiary of
the income, the one that performed the service and is paid a fee,
is the person that is taxable on that fee (the taxpayer). That tax
is paid as a matter of responsibility of the payer of the income,
which the payer
