

资金与金融
对投资者最关心的“能否自由汇回”有明确答案:外汇法原则上不设限制,但必须经由授权中介办理;单笔 10 万美元及以上的汇出须事先向国家银行申报,授权中介亦须向央行报告单笔达到或超过 10 万美元的每一笔转账;出境携带超过 1 万美元等值外汇或本币须向海关申报,超出央行规定限额的现钞出境须经央行事前审查。投资法也明确:投资者有权自由购买外汇并汇出用以清偿与投资相关的财务义务,路径为授权中介银行。清盘所得同样可自由汇出。危机情形下央行可临时限制,但上限 3 个月且延期须政府首脑批准。
There shall be no restrictions on foreign exchange operations through book entry including purchases and sales of foreign exchange on the foreign exchange market, transfers, all kinds of international settlements, and capital flows in foreign or domestic currency, between Cambodia and the rest of the world or between residents and nonresidents.
hundred thousand US dollars (USD 100,000) shall be subject to prior declaration to the Central Bank.
the authorized intermediaries shall report to the Central Bank the amount of each transfer equaling or exceeding one hundred thousand US dollars (USD 100,000).
thousand US dollars (USD 10,000) in foreign exchange or the equivalent amount in domestic currency by a traveler shall be declared to the customs officers at border crossings of the Kingdom of Cambodia.
the Investors are entitled to freely purchase foreign currencies and to repatriate those foreign currencies to settle financial obligations associated with their investment through authorized intermediary banks.
proceeds from said liquidation may be transferred freely.
向境外(非居民纳税人)分配或支付柬埔寨来源所得——包括股息、利息、特许权使用费——时,付款方须按应付金额的 14% 预提所得税(税法 2023 第 26 条);该预提税对收款方为最终税(第 27 条)。第 33 条明确股息、利息、特许权使用费均属柬埔寨来源所得,故汇往境外时落入第 26 条。若是境内居民之间的利息、特许权使用费或服务所得,则按 15% 预提(第 25 条 a 款);境内银行存款利息另有 6%/4% 档。境内企业先分后税(所得税免税期内)的股息分配,另按第 23 条计「股息分配预缴税」(按年度所得税率对分红毛额加成计征)。
Any resident taxpayer carrying on business including permanent establishment of a non-resident taxpayer, who makes the payment for Cambodian source income as stated in Article 33 of this Law to a non-resident taxpayer, shall withhold and pay the tax amount at the rate of 14 (Fourteen) percent of the amount to be paid. This withholding tax does not apply to the gross premiums of reinsurance on the properties, or other risks in the Kingdom of Cambodia.
The rate of 15 (Fifteen) percent on: - Income which person who are not under the self-assessment regime from the performance of services including management or consultation, or similar services - Royalties for intangible assets and equity interests in mineral resources, and interest paid by a resident taxpayer carrying on business other than domestic banks paid to a resident taxpayer.
The withholding tax on payments to a resident taxpayer who is not under the self-assessment regime under Article 25 of this Law and on payments to a non-resident taxpayer under Article 26 of this Law shall be considered the final tax on the recipients of the payments or distributions as stated in other Articles in this Law.
Dividend distributed by a resident enterprise.
Interest paid by a resident enterprise or resident partnership or a governmental institution of the Kingdom of Cambodia.
Royalty from the use, or right to use intangible asset paid by a resident taxpayer, or paid by a non-resident taxpayer through a permanent establishment situated in the Kingdom of Cambodia.