On 4 August 2026, the Ministry of Economy and Finance (“MEF”) issued Notification No. 008 on the Policy of Tax Exemptions and Incentives Regarding the Transfer of Ownership or Possession Rights over Immovable Property (the “Notification”). The Notification implements the instruction of Samdech Thipadei Hun Manet, Prime Minister, set out in Letter No. 7962 dated 28 July 2026, following a dialogue with immovable property owners and citizens held in Ksach Kandal District, Kandal Province, on 24 July 2026.

Suspension of Additional Tax on Late Payment of Registration Tax
Late payment of Registration Tax (Stamp Duty) is in principle subject to additional tax equal to 100% of the tax due. Under the Notification, the application of that additional tax is suspended until the end of 2027 where the three-month period from the date of the transmittal letter or accompanying documents issued by the Capital or Provincial Departments of Land Management, Urban Planning, Construction and Cadastre has been exceeded.

Single Payment of Registration Tax Where Successive Transfers Have Occurred
The Notification extends the effect of Notification No. 367 SCN dated 2 May 2017 issued by the Office of the Council of Ministers. Where an immovable property has a history of successive transfers of possession rights, Registration Tax may be paid once, at the final transfer stage, rather than in respect of each transfer.

The measure is confined to successive transfers of possession rights, and does not extend to transfers of ownership rights. While the title of the Notification and the exemption for military and police personnel both refer to “ownership or possession rights”, this paragraph refers to possession rights alone. Ownership rights pass through the land registration system, where Registration Tax is assessed and recorded on each transfer, so an unaddressed chain of transfers does not accumulate. Unregistered land is different: possession rights are commonly transferred by sale or inheritance without registration at each stage. The measure allows the resulting chain to be regularized by taxing only the final transfer rather than each historical link, which is consistent with the Notification’s stated aim of encouraging the formalization of ownership and the timely completion of land registration procedures.

Simplified Documentation for Registration Tax and Property Tax on Completed Construction
Stamp duty and immovable property tax on completed buildings may be determined on the basis of a construction permit, or a certification of the construction date issued by the relevant competent authorities, simplifying the documentation required to establish the taxable amount.

No Retroactive Effect
The incentives under the Notification do not apply retroactively to tax and administrative penalties (additional tax and interest) that have already been paid.

Implementation Considerations
The measure on successive transfers is of practical significance for purchasers of land whose possession rights have passed through several hands without registration at each stage, a pattern not uncommon in Cambodia. Where such a chain of transfers was completed by July 2026, Registration Tax falls due once on the final transfer; transfers occurring after that point fall outside the measure and are taxed at each stage. Enterprises holding or acquiring land with an unregistered transfer history should review the chain of transfers against this date.

The suspension of additional tax until the end of 2027 offers a window for regularizing positions where the three-month payment period has already been missed. As the incentives have no retroactive effect, amounts already paid cannot be recovered, which makes the sequencing of any remediation relevant. Owners with files currently pending before the Capital or Provincial Department of Land Management, Urban Planning, Construction and Cadastre, or before the tax administration, are accordingly best served by completing those procedures while the measures remain available.

For Assistance
Enterprises and individuals holding immovable property in Cambodia, or contemplating acquisitions, should consult their legal and tax advisors to assess whether the measures under the Notification apply to their circumstances.