Tax residency in Cambodia — 183-day rule

In 3 bullets

• You are a tax resident in Cambodia from 183 days of physical presence over 12 consecutive months (or main home / habitual abode).
• No tax treaty is in force between France and Cambodia as of April 2026 (negotiations started late 2023, not yet signed).
• Without a treaty: real risk of double taxation. France applies its rules, Cambodia applies its own — you must declare in both countries and use unilateral tax credits where available.

The Cambodia residency test

According to the GDT , you are a Cambodian tax resident if one of the three following criteria is met:

1. Main domicile in Cambodia.
2. Habitual abode (centre of vital interests: family, assets, main activity).
3. Physical presence > 182 days over any rolling 12-month period ending in the current tax year.

The Cambodian fiscal year follows the civil year (1 January – 31 December).

Consequences of KH resident status

• Worldwide income taxation in Cambodia (in theory). In practice, the KH administration mostly applies to Cambodian-source income.
• Progressive ToS scale (0-20%) with dependant allowances — see the ToS guide.
• Access to local tax regimes (patent, NSSF declaration, pro VAT).

If you remain KH non-resident (< 183 days)

• 20% flat tax on all Cambodian-source income.
• No allowance, no family quotient.
• No worldwide declaration in KH.

The France residency test

You are a French tax resident if one of the following criteria is met (article 4B of the General Tax Code):

1. Home in France (spouse, children, usual place of living).
2. Main place of stay: more than 183 days in France in the year.
3. Main professional activity carried out in France (unless ancillary).
4. Centre of economic interests in France (investments, assets, main income sources).

These criteria are alternative: one is enough. You can therefore be considered a French resident even spending little time in France, if your family or business is there.

Consequences of FR non-resident status

If none of the above criteria is met, you are a French non-tax-resident. Consequences:

• French taxation only on French-source income (real estate, salaries paid by FR employer for activity in FR…).
• No more family quotient on this FR income.
• Minimum rate of 20% (up to 28,411 € in 2025) then 30% (above). Optionally optimised via average-rate election.
• No taxation on foreign-source income (your KH salary).

The dual-resident trap

You can be considered a resident of both countries simultaneously:

• In KH: > 183 days on the ground.
• In France: family remained in Paris, or centre of economic interests (rental real estate, SCI shares).

Unilateral mechanisms to use

In the absence of a treaty, both countries provide internal mechanisms to mitigate double taxation:

• France side: the unilateral tax credit (CGI art. 244 bis, etc.) on certain income categories, sometimes imputable. Case by case.
• Cambodia side: the GDT has no systematic foreign tax credit, but in practice accepts that income already taxed in France isn’t retaxed if FR-source.
• Optimisation: structure income so it’s clearly single-source, and engage a local firm + an FR tax adviser to validate the declaration.

Documents and declarations to do each year

France side (resident OR non-resident)

Form 3916 reports the existence of bank accounts, e-wallets and life insurance contracts held abroad. Fine: 1,500 € per undeclared account, raised to 10,000 € if the account is in a non-cooperative state (Cambodia is not on the list as of April 2026 but check each year).

Cambodia side

See the patent guide and setting up a company.

Typical cases

Case 1 — EB-visa employee of a KH company, family in France

• KH side: resident from 183 days. ToS withheld at source.
• FR side: potentially still resident (home = family in France). FR authorities may consider the KH salary taxable in France, applying internal rules (tax credit to study).
• Risk: partial double taxation. Solution: consider splitting the home if the KH stay is long-term (cf. tax firm).

Case 2 — ER retiree, spouse in KH

• KH side: resident from 183 days. No KH-source income typically (the pension comes from France).
• FR side: non-resident if spouse with them in KH and no active tie in FR.
• Taxation: pension paid by FR fund → taxable in France at the withholding rate (20% minimum). KH does not tax foreign pensions paid into a foreign account in practice.
• Recommendation: file 2042-NR + 3916 each year, archive pension slips.

Case 3 — EB remote worker, foreign clients

• KH side: resident from 183 days. If you invoice via a KH entity (Co. Ltd. or sole proprietor), KH income → ToS / corporate tax.
• FR side: non-resident if you break the FR home. No FR obligation on KH income.
• Without KH entity: grey situation — the KH administration considers your activity exercised locally (KH tax residency), but you have no employer. Solution: open a sole proprietorship in Cambodia and declare.

Case 4 — Short mission (< 183 days), FR employer salary

• KH side: non-resident → no KH tax on FR salary (unless KH-source in strict sense).
• FR side: resident — you remain FR taxable on everything.
• No double taxation but mind if the employer declares a KH portion of the salary.

Common pitfalls

FAQ

What proof to provide to demonstrate KH residency to the FR tax office?

• Long-stay visa (EB / ER) in force.
• Work permit if you work.
• KH lease or accommodation attestation.
• Recent Sangkat letter.
• KH payslip or employer attestation.
• KH tax notice (annual ToS recap) if available.
• Passport entry / exit stamps (proof > 183 days).

Is the FR-KH treaty close to signing?

Negotiations started late 2023 and the 3rd round took place in January 2025. No public signing date in April 2026 — count several quarters before entry into force after possible signing. Follow news via the Assembly of French Citizens Abroad (AFE) or the Senate (public written questions).

When exactly to switch to FR non-resident to optimise?

If you arrive before 1 July in Cambodia, you can switch to FR non-resident for the same year (under conditions). Otherwise, plan the switch for 1 January following. The FR tax office accepts a mid-year change (split year) but it’s more complex.

Do my children at the French Lycée in PP count as dependants in KH?

Yes — 150,000 KHR / month per dependent child < 14 years (or < 25 if full-time student). Children at LFEPP or an international school fit this. Proof: school certificate.

And CSG / CRDS on my French income?

If FR non-tax-resident, you are exempt from CSG / CRDS on French-source capital income (real estate, dividends), subject to affiliation with an EEA / UK / Switzerland social security regime. Cambodia is not covered by this exemption: you remain liable for CSG/CRDS at full rate (17.2% in 2025).

What to do if I detect double taxation?

1. Document taxes paid on both sides (KH tax notice + 2042 FR).
2. Refer to the SIPNR (Non-Resident Individuals Tax Service) with full file.
3. Request the unilateral tax credit imputation on form 2047 (income received abroad).
4. If refused: hierarchical recourse then administrative court. Without a treaty, the outcome is not guaranteed.

How much does a firm cost to manage all this?

Count:

• KH firm (DFDL, Acclime, VDB Loi, Mekong Strategic Capital…): 50-300 USD/month for a ToS declaration + statements, more for a complex company.
• International FR tax adviser: 500-1,500 € for a 2042-NR + 3916 + 2047 declaration, more for asset-planning optimisation.