The General Department of Taxation announced on 11 September 2026 the commencement of the second round of negotiations for a Double Taxation Agreement (DTA) between Cambodia and the United Arab Emirates. The negotiation aims to eliminate double taxation on income and capital, prevent fiscal evasion, and provide certainty for cross-border investors and businesses operating between the two jurisdictions. The first round laid the groundwork on key articles covering residence, permanent establishment, business profits, dividends, interest, royalties, and capital gains. The second round will focus on unresolved technical issues, anti-abuse provisions, and the exchange of information article aligned with OECD standards.
Key Takeaways
- Investment Facilitation: The DTA will provide clear taxing rights allocation, reducing withholding tax rates on dividends, interest, and royalties, thereby encouraging bilateral investment flows.
- Anti-Abuse Measures: Negotiations include incorporation of Principal Purpose Test (PPT) and Limitation on Benefits (LOB) clauses to prevent treaty shopping and ensure substance requirements.
- Exchange of Information: The agreement will adopt the OECD standard for automatic and on-request exchange of tax information, enhancing transparency and compliance for both tax administrations.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement