Transfer Pricing in Cambodia: Basics Every CFO Should Know

Who is in scope

Any taxpayer with related-party transactions, whether cross-border or domestic, must comply. There is no de minimis threshold in the regulation itself, though documentation requirements scale with materiality.

Acceptable methods

The five OECD methods are accepted: comparable uncontrolled price, resale price, cost plus, transactional net margin, and profit split. Choice of method must be justified in the documentation.

Documentation

Maintain contemporaneous transfer pricing documentation including a master file and a local file. The GDT may request these during audit and short deadlines apply.

How to Verify the MEF Rate for Your Filing

Whether you are posting a USD invoice, computing month-end FX revaluation, or preparing a customs declaration, the rule is the same: anchor your figure to the official MEF daily bulletin for the relevant valuation date. Use today's official MEF rate from the Cambodia Exchange dashboard for live work, or pick any past date to retrieve the exact rate that applied on that day. Archive the rate evidence (a screenshot or API response) alongside the supporting document — GDT auditors increasingly request the source for every FX translation.

For the full data-handling disclosure — including caching, timezone normalization to Indochina Time, and how weekend/holiday fallbacks work — see our data methodology. For binding tax or customs positions, cross-check against the MEF bulletin directly and consult a licensed Cambodian tax advisor.

Frequently Asked Questions

Does Cambodia have transfer pricing rules?

Yes. Cambodian transfer pricing rules require related-party transactions to be priced at arm's length and supported by appropriate documentation. The specific requirements have evolved over recent years — confirm the current rules with a Cambodian tax advisor before filing.

Which related-party transactions does this typically cover?

Cross-border sales of goods and services, intercompany loans, royalty and management-fee arrangements, and any other transaction between connected entities that affects taxable profit in Cambodia.

How does FX translation interact with transfer pricing?

Intercompany balances and pricing usually need to be stated in a consistent reference currency and translated using the MEF rate for the relevant date. Documenting the FX methodology is as important as documenting the pricing methodology itself.

អត្ថបទនេះមានប្រយោជន៍មែនទេ? ចែករំលែកជាមួយក្រុមរបស់អ្នក ឬ ផ្ញើមតិមកយើង។