TOI — corporate income tax in Cambodia

In 3 bullets

• Tax on Income (TOI — formerly Tax on Profit) is levied on the taxable profit of any entity registered in Cambodia, at a standard rate of 20% (Law on Taxation, art. 20).
• A Minimum Tax of 1% of annual turnover (inclusive of all taxes except VAT) applies — unless you keep proper accounting records (Tax on Income — GDT).
• You pay a monthly Prepayment of ToI of 1% of monthly turnover, creditable against the annual TOI. Return and balance due by 31 March (3 months after year-end).

Who is concerned

TOI applies to any legal or physical person carrying out an activity that generates Cambodian-source profit:

• Companies: Co. Ltd., Single Member Co. Ltd., PLC, branch of a foreign company.
• Sole proprietors above the small-taxpayer thresholds.
• Permanent establishments of foreign entities with activity in Cambodia.

A pure Representative Office has no Cambodian-source profit: in principle it is not liable to TOI (no local turnover allowed). See the business-structures guide.

The TOI rate

Standard rate: 20%

The standard rate is 20% of taxable profit for medium and large taxpayers, legal persons and permanent establishments (Law on Taxation, art. 20).

Progressive rate for small taxpayers

Small taxpayers (sole proprietors, some small structures) are taxed on a progressive scale on annual profit, mirroring the physical-person scale (art. 20, Law on Taxation):

It is progressive by bracket: only the profit above each threshold is taxed at the higher rate.

Special rates

Source: Law on Taxation, art. 20 and Tax on Income — GDT.

The Minimum Tax

The Minimum Tax (MT) is a floor distinct from TOI:

• Base: 1% of annual turnover, inclusive of all taxes except VAT.
• Principle: you pay the higher of the two — TOI computed on profit or the Minimum Tax — even in a loss position (Tax on Income — GDT).

Key exemption: since 1 January 2017 (2017 Law on Financial Management), the Minimum Tax no longer applies to enterprises that keep proper accounting records. In practice, “proper accounting records” is not precisely defined by the GDT and is assessed case by case during an audit.

The monthly Prepayment (Prepayment of ToI)

Most commercial enterprises pay a monthly Prepayment of Tax on Income (PToI):

• Base: 1% of the month’s turnover, inclusive of all taxes except VAT.
• Deadline: by the 20th day of the following month, via the online GDT portal.
• Crediting: the prepayment is creditable against the annual TOI and against the Minimum Tax. Any overpayment becomes a carry-forward tax credit.

Source: Tax on Income — GDT.

Computing taxable profit

Taxable profit starts from the accounting result, adjusted for tax rules:

• Income: turnover + other income (capital gains, FX gains, etc.).
• Deductible expenses: costs incurred for the business and substantiated — including the patent tax and the employer’s ToS.
• Non-deductible expenses: lavish spending, fines/penalties, certain unsubstantiated costs, interest beyond the legal cap.
• Depreciation: per the categories and rates set by regulation (special depreciation possible under QIP).

Loss carry-forward (5 years)

A tax loss can be carried forward for 5 years (Law on Taxation). Main conditions:

• No carry-back: not permitted.
• Continuity of activity: the carry-forward is lost if the business changes its activity.
• On a unilateral reassessment by the GDT, brought-forward losses cannot be offset in the reassessed year.

Capital gains — 20%

Cambodia introduced a Capital Gains Tax at 20% of the net gain, with a phased entry into force:

• Disposals of shares and other assets (excluding real estate): taxable since 1 January 2026.
• Immovable property held by physical persons: implementation deferred to 1 January 2027 (MEF Prakas).

For companies, capital gains are in principle included in taxable profit subject to TOI at 20%. The TOI / capital-gains boundary is evolving — have your case validated by a local firm.

Filing and payment

• Tax year: by default the calendar year (1 January – 31 December). A different year-end may be granted on application to the GDT.
• Annual TOI return: filed within 3 months of year-end, i.e. before 31 March for a calendar-year period.
• Balance payment: due on the same deadline as the return (31 March).
• Monthly prepayment (PToI): 1% of turnover, by the 20th of the following month.
• Channel: the tax.gov.kh/en/e-service portal, Tax on Income – ToI e-Filing section, or a partner bank (ABA, ACLEDA, Canadia…).

TOI is filed and paid under the company TIN, the same one used for the patent, ToS and VAT. See the tax-residence guide for how it fits your personal situation.

Required documents

For the annual TOI return:

• Financial statements for the year (balance sheet, income statement) in Khmer and riel.
• General ledger and supporting vouchers (kept for 10 years).
• Detail of the monthly prepayments (PToI) already paid, to be credited.
• Company TIN + GDT portal access.
• Where relevant, the QIP certificate and the special-depreciation schedule.

Common pitfalls

FAQ

TOI, Tax on Profit, corporate income tax: same thing?

Yes. The official name moved from Tax on Profit (ToP) to Tax on Income (TOI) with the overhaul of the Law on Taxation. It is also called corporate income tax (CIT). The standard rate stays at 20%.

I’m a freelancer as a sole proprietor — do I also pay 20%?

Not necessarily. A sole proprietor classified as a small taxpayer is on the progressive scale (0% to 20%) on profit, not the flat 20%. Above the small-taxpayer thresholds, or if you switch to a company, the standard 20% applies. See the business-structures guide.

How do I avoid the 1% Minimum Tax on turnover?

By keeping proper accounting records: registers in Khmer and riel, complete entries, vouchers kept 10 years. Enterprises with proper records have been exempt from the Minimum Tax since 2017 and pay only TOI on actual profit. As the notion remains fuzzy, use a licensed accounting firm.

What if my prepayments exceed my annual TOI?

The monthly prepayments (1% of turnover) are credited against the annual TOI. If total prepayments exceed the tax due, the excess becomes a tax credit you carry forward to later years (cash refunds exist but are slow). Common for low-margin activities.

What does a firm cost to handle TOI?

Count 50-200 USD / month for a small Co. Ltd. at a local firm (TOI, VAT, ToS, patent, NSSF, annual statements included). 300-1,000 USD / month at an international firm (DFDL, Acclime, KPMG, PwC, VDB Loi) with audit, advisory and group reporting. The annual TOI return alone can be billed separately.

Are gains on selling my company taxed?

Cambodia taxes capital gains at 20%. Share disposals are taxable since 1 January 2026; individuals’ real estate is deferred to 2027. For a company, the gain generally falls within taxable profit subject to TOI. The regime is evolving — validate before any major disposal.