Cambodian tax residency — the 183-day rule

In 3 bullet points

• You become a Cambodian tax resident after 183 days of cumulative physical presence over a rolling 12-month period — or if Cambodia is your domicile or centre of vital interests.
• As a resident, your worldwide income is theoretically taxable in Cambodia via the progressive ToS (Tax on Salary) — rates from 0 to 20 %.
• No tax treaty is in force between France and Cambodia as of June 2026: real risk of double taxation on pensions, rental income, and supplementary retirement benefits.

The Cambodian residency test

According to the GDT , you are a Cambodian tax resident as soon as any one of these three criteria is met:

1. Principal domicile in Cambodia.
2. Habitual place of stay: your daily life (family, assets, main activities) is centred in Cambodia.
3. Physical presence > 182 days over any rolling 12-month period ending within the current fiscal year.

Cambodia’s fiscal year follows the calendar year (1 January – 31 December).

Practical examples

Consequences of resident status

Worldwide income taxation

As a Cambodian tax resident, you are theoretically taxable on your entire worldwide income via the ToS:

• French or foreign pension (CNAV, AGIRC-ARRCO, civil service, etc.)
• Salary from a foreign employer (remote workers)
• Rental income received in France
• Dividends, capital gains on foreign accounts
• Any other income source, regardless of the country of payment

The applicable rate is the progressive ToS bracket: 0 % up to ~USD 366/month, then 5 %, 10 %, 15 % and 20 % on successive brackets. See the ToS rates for individuals guide for the full calculation.

Flat-rate taxation of non-residents

If you are not a Cambodian tax resident but receive income from a Cambodian source (Cambodian employer, rental of a Cambodian property), that income is taxed at a flat 20 % — no brackets, no allowances.

The French side — becoming a non-resident

Leaving French tax residency is a separate step, necessary to avoid being taxed in both countries.

French tax residency criteria

Under Article 4B of the French Tax Code, you remain a French tax resident if:

• Your home or principal place of stay is in France.
• You carry on a principal professional activity in France.
• Your main economic interests are in France.

If you leave permanently for Cambodia and no longer meet any of these conditions, you can legally become a French non-resident.

Steps to become a French non-resident

1. File a departure-year tax return (Form 2042 + 2042 C), specifying your departure date.
2. Contact the SIPNR (Non-Resident Individual Tax Office): it manages your French-source income from the following year onward.
3. Notify your pension fund (CNAV, AGIRC-ARRCO, etc.) of your change of address: it will apply the non-resident withholding tax (PAS NR) to your pension.
4. Declare any foreign bank account via Form 3916 (including ABA Bank, Canadia, etc.). Penalty: EUR 1,500 per undeclared account, over 10 years.

No France-Cambodia tax treaty

No bilateral tax treaty is in force between France and Cambodia as of June 2026 (negotiations began late 2023, not yet signed). The absence of a treaty means:

• No automatic mechanism to eliminate double taxation.
• Both countries apply their own rules independently.
• A unilateral tax credit may sometimes be available in France (Form 2047) if you actually pay ToS in Cambodia, but it is not guaranteed.

Track progress of negotiations through the Assemblée des Français de l’Étranger (AFE) or written questions in the French Senate.

First year of arrival — beware of the proration

If you arrive in Cambodia during the year (typically after July), you will likely not reach 183 days before 31 December. You will therefore be a non-resident for tax purposes in KH that first year:

• Cambodian-source income (if any): taxed at a flat 20 %.
• Foreign income: not taxable in Cambodia.
• From the following year, if you stay more than 182 days, you become resident and your worldwide income becomes taxable.

Common pitfalls

FAQ

How do I prove I am no longer a French tax resident?

By declaring your departure to the SIPNR, providing your Cambodian lease or proof of accommodation, and ensuring that your principal home (family, assets, economic ties) is effectively in Cambodia. In case of an audit, proof of physical presence (bank card statements, flight tickets, consular residence certificates) may be requested.

I spend 6 months in Cambodia and 6 months in France. What is my tax status?

An ambiguous situation. If you are exactly at 182 days on each side, France applies its own criteria (home, economic interests) and Cambodia does the same. Without a treaty, both countries may claim tax residency. Consult a specialist in French international taxation.

Do I have to pay ToS if I only receive a foreign pension?

Theoretically yes, if you are a Cambodian tax resident. See the foreign pension guide for the full breakdown. In practice, the GDT does not pursue foreign pensions received in foreign accounts — it is a tolerated grey area but not legal.

What if I freelance for foreign clients from Cambodia?

As a Cambodian tax resident, your freelance income is taxable in Cambodia even if your clients are abroad and pay into a foreign account. The standard approach is to register as a “sole proprietor” with the GDT and file monthly. See the GDT filing guide.

Since when have France-Cambodia negotiations been under way?

First official talks took place in late 2023, with a third round of negotiations in January 2025. No signing date has been made public as of June 2026. The convention, once signed, will still need to be ratified by both parliaments before it takes effect.