分享在
激励措施和计划
According to Article 24 of the Law on Investment of the Kingdom of Cambodia, 19 sectors and activities are entitled to investment incentives:
High-tech industries involving innovation or research and development;
Innovative or highly competitive new industries or manufacturing with high added value;
Industries supplying regional and global production chains;
Industries supporting agriculture, tourism, manufacturing, regional and global production chains and supply chains;
Electrical and electronic industries;
Spare parts, assembly, and installation industries;
Mechanical and machinery industries;
Agriculture, agro-industry, agro-processing industry, and food processing industries serving the domestic market or export;
Small and medium-sized enterprises in priority sectors and small and medium-sized enterprise cluster development, industrial parks, and science, technology, and innovation parks;
Tourism and tourism-related activities;
Special economic zones;
Digital industries;
Education, vocational training, and productivity promotion;
Health;
Physical infrastructure;
Logistics;
Environmental management and protection, biodiversity conservation, and the circular economy;
Green energy, technology contributing to climate change adaptation and mitigation;
Other sectors and investment activities not listed by this Law deemed by the Royal Government of Cambodia to have the potential for socio-economic development.
Basic Incentives
Investment activities registered as QIP are entitled to choose basic incentives under the following two options:
1- Option 1, will receive the following incentives:
A- Tax on Income exemption starting from the time of receipt of first revenue from the business activity during a specific period according to the Investment Activity Category that is stated in the list of Investment Activity in Annex 2 of the Sub-Decree as follows:
9 (nine) years for Group 1;
6 (six) years for Group 2;
3 (three) years for Group 3.
B- Entitlement to the incentive to pay Tax on Income at a progressive rate proportional to the total amount of tax due after the expiration of the Tax on Income exemption period:
25 (twenty-five) percent for the first 2 (two) years;
50 (fifty) percent for the next 2 (two) years; and
75 (seventy) percent for the last 2 (two) years;
C- An exemption for the Prepayment of Tax on Income during a specific period according to the Investment Activity Category as stated in the list of Investment Activity of Annex 2 of the Sub-Decree as follows:
9 (nine) years for Group 1;
6 (six) years for Group 2;
3 (three) years for Group 3.
D- A Minimum Tax exemption provided that an independent audit report has been obtained.
E- An export tax exemption, unless otherwise stated in other laws and regulations.
2- Option 2, will receive the following incentives:
A- Entitlement to deduct capital expenditure through special depreciation as stated in the applicable provisions on taxation.
B- Entitlement to deduct up to 200 (two hundred) percent of certain expenses within a specific period according to the Investment Activity Category as stated in the list of Investment Activity in Annex 2 of the Sub-Decree as follows:
9 (nine) years for Group 1;
6 (six) years for Group 2;
3 (three) years for Group 3.
– Certain expenses include:
Expenses for training on specific skills for Cambodian employees to
substitute foreign employees;
Expenses for using accounting books via an information technology system;
Expenses for providing scholarships to Cambodian employees to study certain skills abroad;
Expenses for the study, research and development, and hiring of foreign experts to provide training on new technologies, Industry 4.0, including artificial intelligence and robotics, or the arrangement of big data storage.
C- An exemption for Prepayment of Tax on Income for a specific period according to the Investment Activity Category as stated in the list of Investment Activity in Annex 2 of the Sub-Decree as follows:
9 (nine) years for Group 1;
6 (six) years for Group 2;
3 (three) years for Group 3.
D- A minimum tax exemption provided that an independent audit report has been obtained.
E- An export tax exemption, unless otherwise stated in the other laws and regulations.
In addition to the incentives of the 2 (two) options above:
A QIP that has the right to import Construction Material, Construction Equipment, and Production Equipment to serve its production line will have customs duty, special tax, and value-added tax exemption,
In addition to Item 1 of this Paragraph, an Export QIP or Supporting Industry Export QIP that has the right to import the Production Inputs to serve its production line will have customs duty, special tax, and value-added tax exemption. In the case that Production Inputs are not used to supply the production line, the Export QIP or the Supporting Industry Export QIP must pay customs duty, special tax, and value-added tax in accordance with the applicable laws and regulations.
Except otherwise provided in the law, any Investment Activity covered by Annex 3 of the Sub-Decree shall be granted with incentives to import the Construction Material, the Construction Equipment, and the Production Equipment for its production line and the customs duty, special tax, and value-added tax exemption, but shall not be granted with the tax incentives after obtaining a Registration Certificate certifying a QIP status as stated in the Law on Investment of the Kingdom Cambodia.
The Domestically Oriented QIP with the Investment Activity covered under Annex 4 of the Sub-Decree that has the right to import the Production Inputs for its production line will have customs duty, special tax, and value-added tax exemption.
The Domestically Oriented QIP that can directly export or supply the Production Inputs to the Export QIP of any part of the products made from the imported Production Inputs and having fulfilled the tax obligations will be refunded or reserved for the payment of customs duty, special tax and value-added tax on goods to be imported at a later date according to the applicable laws, regulations, and procedures at the request of the Investor.
Additional Incentives
In addition to the basic, a QIP shall
receive the following additional incentives:
A QIP is exempted from value-added tax on the purchase of locally produced Production Inputs for the implementation of the QIP. This value-added tax exemption shall apply at the rate of 0 (zero) percent.
A QIP receives a deductible expense at the rate of 150 (one hundred and fifty) percent from the tax base for any of the following activities:
A. Research, development, and innovation.
B. Human resources development through the provision of vocational training and skills to Cambodian workers/employees.
C. Construction of accommodation, canteens, free of charge, or affordable food courts, nurseries, and other facilities for workers/employees.
D. Modernizing machinery to serve the production line.
E. Offering welfare promotion to Cambodian workers/ employees, such as providing comfortable means of transportation for workers to travel from their accommodation to the factory, accommodation, canteens, free of charge or affordable food courts, nurseries, and other facilities.
F. Investment or construction of infrastructure for all types of waste treatment, including solid waste, hazardous waste, liquid waste, and smoke.
3- A QIP that has the right to import the Construction Material and the Construction Equipment for the construction of accommodation, nurseries, first aid rooms, canteens, free of charge or affordable food court only for the workers of its Investment Project located at the premises of the Investment Project, will have customs duty, special tax, and value-added tax exemption
Additional Incentives for Expanded- Qualified Investment Project (EQIP)
The incentives shall be granted to the EQIP in accordance with the following:
A QIP with the request to expand the Investment Activity shall be entitled to receive an incentive on Tax on Income exemption period if the expanded project takes any of the following forms:
A. Expansion of the existing production.
B. Expansion through product line diversification within the same line.
C. Expansion through the installation of new and modern technologies that increase productivity or protect the environment.
If the project expansion takes any other form, a permit from the Royal Government must be obtained.
From the time of QIP expansion, the EQIP shall be entitled to obtain the Tax on Income exemption according to the original Investment Activity within a specific period according to the Investment Activity Category as specified in the list of Investment Activities of Annex 2 of the Sub-Decree as follows:
A. 9 (nine) years for Group 1;
B. 6 (six) years for Group 2;
C. 3 (three) years for Group 3.
3. The part of revenue to be exempted from tax for an EQIP is equal to the total taxable income multiplied by the rate of EQIP Capital. The rate of EQIP Capital is equal to the EQIP Capital divided by the total Investment Capital. The total Investment Capital is equal to the Investment Capital of the initially registered QIP plus the EQIP Capital to be granted with the incentive. The calculation formula is as follows:
I TOIE = TTI x (EIC/TIC)
I TOIE = Income with Tax on Income Exemption
TTI = Total Taxable Income
EIC = EQIP Capital to be granted with Incentive
TIC = Total Investment Capital (IIC + EIC)
IIC = Initial Investment Capital of QIP
Prepayment of the Tax on Income for EQIP shall be exempted based on the proportion of the rate of EQIP Capital within the Tax on Income exemption period on the EQIP.
EQIP is entitled to a minimum tax exemption provided that an independent audit report has been obtained.
Special Incentives:
Any specific sector and investment activities having high potential to contribute to national economic development may receive specific special incentives to be set out in the Law on Financial Management.
