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Cambodia's New Transfer Pricing Regulations from 2025

06 December 2024

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Approved Changes

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Cambodia

Cambodia's Ministry of Economy and Finance has issued Prakas 574 of 19 September 2024, which establishes new transfer pricing regulations with effect from 1 January 2025. Some of the key changes include: The definition of "related party" is revised to include parties that directly or indirectly control or are controlled by the taxpayer, or parties under common control with the taxpayer (generally 20%), as well as permanent establishments and their non-resident parents (owners); New provisions are introduced regarding the attribution of profits to permanent establishments in line with the OECD Transfer Pricing Guidelines; New provisions are introduced regarding transfer pricing...