Cambodia — Tax Residency (183 Days / Any 12 Months)
Summary
- Day threshold
- More than 182 days
- Window
- Any 12 months ending in the current tax year
- Triggers on
- Day 183 — track a 182-day cap
- Tracked as
- Every rolling 365-day window
- Also triggers
- Residence or principal place of abode (no day count)
- Partial days
- Not addressed — count them
- Basis
- Law on Taxation 2023, Arts. 5, 42, 167
- Authority
- General Department of Taxation (GDT)
Cambodia treats you as a resident taxpayer once you are present for more than 182 days in any 12-month period ending in the current tax year. Because the trigger is “more than 182”, the last safe count is 182 and day 183 crosses the line. The window is rolling, not calendar — so days from late last year can make you resident in the new tax year even if you have barely arrived. A residence or principal place of abode in Cambodia does it with no day count at all.
Who it applies to
This matters most if you are:
- A remote worker or consultant based part of the year in Phnom Penh or Siem Reap.
- Someone rotating around Southeast Asia whose Cambodian stays are long but split across New Year.
- An expatriate on assignment whose employer withholds at the nonresident flat rate by default.
- A business owner with a Cambodian apartment kept year-round.
The rolling window is what catches people. A stay from September to March never reaches 183 days in either calendar year — but the 12-month window ending in March holds all of it.
The rule — and why it exists
The Law on Taxation 2023 (Royal Kram NS/RKM/0523/004, promulgated 16 May 2023) defines a resident taxpayer in identical wording at Articles 5, 42 and 167:
“‘Resident Taxpayer’ means: a — Any physical person who has residence in or has principal place of abode in the Kingdom of Cambodia, or who is present in the Kingdom of Cambodia more than 182 (One hundred and eighty-two) days in any period of 12 (Twelve) months ending in the current tax year.”
Three routes, then, and only one of them counts days:
- Residence in Cambodia — no day count.
- Principal place of abode in Cambodia — no day count.
- More than 182 days in any 12-month period ending in the current tax year.
The phrase “ending in the current tax year” is often misread as a calendar-year reset. It is not. It identifies which tax year the residency attaches to. A live trailing window always ends in the current tax year, so in practice every rolling 12-month window has to stay under the cap.
Why it exists: Article 254 of the 2023 law abrogated the 1997 law and its 2003 amendment, modernising a code that predated Cambodia’s current expatriate and investment economy. The rolling window is the standard anti-avoidance shape: it stops a long stay being laundered through a New Year boundary.
Counting the days
- 1Count every day of presence in Cambodia. The law is silent on partial days, so count any part of a day as a full day.
- 2The window is any 12-month period ending in the current tax year — it slides forward and never resets.
- 3Residency attaches once the total in any such window exceeds 182 — that is day 183.
- 4Bounded checks every rolling 365-day window against a 182-day cap, so the breach fires on day 183 in whichever window reaches it first.
- 5Watch January in particular: a window ending just after 1 January still holds last year's days.
The leap-year caveat. Twelve months is approximated as 365 days. In a span containing 29 February, 183 days can sit at 182 in every 365-day window without formally breaching. Treat reaching the cap as being at the line rather than one day short of it.
Examples
Example 1 — the clean count
Sophea spends 170 days in Phnom Penh across the year in three blocks, in serviced apartments taken trip by trip, and lives in Singapore. No rolling window exceeds 182 and she has no Cambodian abode. She is a nonresident taxpayer.
Example 2 — January carry-over
James arrives in mid-August and stays through to late February — about 190 days. Neither calendar year holds 183, but the 12-month window ending in February holds all of them. He is a resident taxpayer for that tax year, on the strength of days most of which fell in the previous one.
Example 3 — resident on very few days
Chantha keeps a house in Siem Reap as her base and works abroad for most of the year, spending 70 days in Cambodia. Her principal place of abode is there, so she is a resident taxpayer on the first limb and the count is irrelevant.
Exceptions & edge cases
- Abode beats days. A residence or principal place of abode in Cambodia makes you resident regardless of presence. If you keep a home there, do not plan around the counter.
- Partial days are unlegislated. No provision tells you how to treat an arrival evening. Counting them is the safe assumption and the one Bounded makes.
- Salary withholding is separate. Cambodian employers withhold tax on salary monthly. Your residency status changes the rate and the base, but the mechanics are handled through payroll, so a change of status mid-year needs to be communicated.
- The English text is unofficial. The Khmer original of the Law on Taxation prevails. The widely circulated English translation is labelled as unofficial — sound for the numbers, but not the text a dispute would turn on.
- Treaty network is thin but growing. Cambodia has a small number of double tax agreements. Do not assume treaty relief is available on a short assignment.
Common misconceptions
- "183 days in a calendar year." Two errors in one. It is more than 182, and the window is any rolling 12 months, not the calendar year.
- "Leaving before 31 December clears my days." It does not. A window ending in January still contains the autumn.
- "The 1997 tax law is still the reference." Article 254 of the 2023 law abrogated it, along with the 2003 amendment.
- "No lease, no residency risk." A principal place of abode is a factual concept that does not require a lease in your name.
- "Half-days do not count." The law does not say either way, which is a reason to count them, not to ignore them.
Related: Vietnam runs a similar dual-window test, and Thailand a calendar-year one — worth comparing if you rotate around the region.
Questions fréquentes
The statute says "more than 182 days", so 182 is safe and day 183 triggers residency. Bounded caps the counter at 182 and fires on 183, landing exactly on the statutory line.
Rolling. Article 5 of the Law on Taxation 2023 counts presence "in any period of 12 months ending in the current tax year". The 12-month window can end on any date in the tax year, so it slides — it does not reset on 1 January. What the tax-year phrase fixes is which year the residency attaches to, not when the counting starts.
Residents are taxed on worldwide income; nonresidents only on Cambodian-source income. Salary is taxed at progressive rates for residents and at a flat 20% withholding for nonresidents, so the direction of the change depends on how much you earn.
Yes. The same definition makes you a resident taxpayer if you have a residence in Cambodia or your principal place of abode is there — no day count applies to either. A long-term apartment that is clearly your base can settle the question on its own.
The Law on Taxation promulgated by Royal Kram NS/RKM/0523/004 on 16 May 2023. Article 254 abrogates the 1997 law (NS/RKM/0297/03) and its 2003 amendment. Guidance written against the older law may still be accurate on the numbers but cites a repealed statute.
The law does not say how partial days are treated. In the absence of a rule, count any part of a day as a full day — that is the conservative reading, and it is what Bounded does.
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Bounded
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Sources
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