The Prakas No. 192/SHV/BRK/GDT on Tax Rules and Procedures for Trust, issued by the Ministry of Economy and Finance on March 12, 2025 ("Prakas No. 192"). It introduces new tax rules and procedures for trust transactions in Cambodia and imposes certain tax implications on trustees, beneficiaries, and trustors participating in trusts created in Cambodia, whether they are residents or not.

1. Tax registration

Trustees who are or will be formed as legal companies must register as medium or large taxpayers with the appropriate tax authorities.
Those who have earned a trustee license must also be registered as small, medium, or legal taxpayers with the appropriate tax authorities.
If the trustee (person or firm) satisfies the requirements, they must register with the appropriate tax authority within 15 working days of starting their business or receiving permission or a license from the Trust Regulator, whichever comes first.

2. Accounting

Trustees are required to keep distinct accounting records for their activities linked to the trust and to adhere to the tax filing regulations for transactions involving the trust, which include keeping distinct records for every trust.
The assets that a trustee owns and the assets they hold in trust should be clearly separated.
Trustees shall follow the accounting regulations in accordance to Article 6 of the Law on Taxation (2023).

3. Tax

Tax on income: Trustees are subject to the Tax on Income (TOI) on any compensation or commissions they earn for overseeing trust transactions. Under the terms of the trust deed, funds or properties that the trustor transfers to the trustee for administration and safekeeping are not regarded as trustee income. TOI taxes: 20% for legal entities; progressive taxes ranging from 0% to 20% for individuals, sole proprietorships, and each partner.

Tax on Immovable Property Rentals: Trust property rental revenue is subject to tax. Trustees are required to file the tax return, pay the tax to the tax authority, and record the rental revenue of the trust property.

Capital gain tax: Gains from the sale or transfer of trust property are liable to capital gain tax, or CGT. Trustees must file a tax return, pay taxes to the tax authority, and record any capital gains from the sale or transfer of trust property.

Stamp Duty: Stamp duty applies to transfers of ownership or possession rights. Trustees are required to file the tax return, pay the tax to the tax authority, and record the rental revenue of the trust property.

Withholding Tax (WHT): Unless otherwise subject to CGT, transfers of any income from a trust property to a non-resident are liable to WHT.