Tax & Transfer Pricing 14th Sep, 2026

Cambodia and Myanmar: Sign Double Taxation Agreement

On 11 September 2026, Cambodia’s General Department of Taxation (“GDT“) announced the signing of the Agreement between the Governments of Cambodia and Myanmar for the Elimination of Double Taxation with Respect to Taxes on Income and the Prevention of Tax Evasion and Avoidance (“DTA“) in Phnom Penh.

The DTA is intended to eliminate double taxation, enhance tax certainty, and facilitate cross-border trade and investment between Cambodia and Myanmar. It also establishes a framework for allocating taxing rights, administrative cooperation, exchange of information, and the prevention of tax evasion and avoidance.

For Cambodia, Myanmar becomes its ninth ASEAN treaty partner and the 14th jurisdiction with which Cambodia has signed a DTA.

For Myanmar, the DTA is particularly significant as it will be Myanmar’s 12th signed tax treaty (with eight currently in force) and its seventh treaty with an ASEAN member state (with five currently in force). It is also only the second new DTA concluded in recent years, following the Myanmar-Belarus DTA, which entered into force on 15 July 2026 and will apply in Myanmar from 1 April 2027. The signing reflects Myanmar’s continued efforts to expand its tax treaty network and strengthen regional economic integration.

Once effective, the DTA is expected to improve tax certainty, reduce double taxation, support cross-border investment, and potentially provide reduced withholding tax rates on certain cross-border payments, subject to the final treaty provisions.

Entry into Force

The Cambodia-Myanmar DTA is not yet effective. It will enter into force only after both countries complete their respective ratification procedures and exchange the required instruments and notifications under the treaty.

The GDT also noted that Cambodia has completed DTA negotiations with France and continues treaty negotiations with several jurisdictions, including Japan, Morocco, the United Arab Emirates, Qatar, and Azerbaijan.

DFDL will continue to monitor developments and provide updates once the Cambodia-Myanmar DTA is ratified and the treaty text becomes available. Our tax teams in Cambodia and Myanmar remain available to discuss the potential implications of the DTA for your business.

Tax services required to be undertaken by a licensed tax agent in Cambodia are provided by Mekong Tax Services Co., Ltd., a member of DFDL and licensed as a Cambodian tax agent under Licence No. TA201701018.