The income tax treaty between Cambodia and Hong Kong entered into force on 27 December 2019. The treaty, signed 26 June 2019, is the first of its kind between the two jurisdictions. Taxes Covered The treaty covers Cambodian tax on income including withholding tax, minimum tax, additional profit tax on dividend distribution, and capital gains tax, and tax on salary. It covers Hong Kong profits tax, salaries tax, and property tax. Service PE The treaty includes the provision that a permanent establishment will be deemed constituted when an enterprise furnishes services through employees or other engaged personnel if the activities...