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GDT’s recent action on VAT on E-commerce

GDT’s recent action on VAT on E-commerce

October 24, 2022

As noted in a number of our previous tax alerts, implementation of VAT on e-commerce began in April 2022. Under the self-assessment regime, the regulations require that taxpayers apply the VAT reverse charge system to declare and pay 10% VAT to the General Department of Taxation (“GDT”) on any digital goods, services or e-commerce activities supplied by non-residents. Failure to comply with the regulations will result in additional tax, penalties, and interest being imposed on the undeclared items.

Recently, the GDT began taking action on this matter by reviewing what taxpayers declare in the e-filing system and comparing the amount declared for 14% Withholding Tax (“WHT”) with that declared for VAT reverse charges. If there are any discrepancies, the GDT will issue a Notice of Tax Assessment for the difference. We know of many taxpayers that have already received such a notice from the GDT.

Given the above, we strongly suggest that you carefully review your 14% WHT declarations to determine whether there are any items that would be considered as a digital good or service so that you can correctly declare the VAT reverse charges. Proper declaration of VAT reverse charges will not only save you from having to pay penalties and interest but also allow you to claim the declared VAT as an input credit.


An ACCA-qualified adviser, Sivila is an expert in Cambodian taxation with over 10 years of tax consulting experience, including several years with Big 4 firm KPMG.

At VDB Loi, he advises on tax structuring, disputes, and controversy, and conducts tax due diligence for clients across a range of industry sectors, including financial services, telecommunications, real estate, and garment manufacturing.

Sivila is also an associate member of the Kampuchea Institute of Certified Public Accountants and Auditors (KICPAA).

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