The income tax treaty between Cambodia and Thailand entered into force on 26 December 2017. The treaty, signed on 7 September 2017, is the first of its kind between the two countries. Taxes Covered The treaty covers Cambodian tax on profit, including withholding tax, additional profit tax on dividend distributions and capital gains tax, and tax on salary. It covers Thai income tax and petroleum income tax. Permanent Establishment 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 continue for the same...