Tax audits in Cambodia: Types, process & required documents.

This is the ultimate guide to tax audits in Cambodia.

Tax audits are conducted to review accounting records, financial reports and documents related to the taxpayers’ business to certify that the tax declaration and tax payment are accurate and compliant in accordance with the law and regulations on taxation.

Let’s find out more about tax audits.

Types of tax audits in Cambodia

There are three types of tax audits in Cambodia, which are:

• Desk tax audit
• Limited tax audit
• Comprehensive tax audit

Desk tax audit

A desk tax audit is a re-examination of tax returns conducted by a tax officer at the tax department office.

It may be initiated if the officer suspects any inaccuracies, they will request supporting documents and clarification from the taxpayer. In addition, if the tax officer decides that it is complex or high risk, the desk audit may be terminated and replaced by an onsite tax audit.

The desk audit can be carried out within 12 months after the submission of tax returns.

Limited tax audit

A limited tax audit is an onsite tax audit at the taxpayer’s business premises and is a thorough re-examination on most types of tax including, Value-Added Tax (VAT) refund but excluding tax on income.

The limited tax audit can be conducted for the current tax year (N) and the preceding tax year (N-1).

Comprehensive tax audit

A comprehensive tax audit is conducted at the taxpayer’s business premises, and it is the most detailed re-examination on all types of taxes and includes an assessment of the taxpayer’s accounting records.

A comprehensive tax audit can be carried out within three tax years of a tax return being lodged (N-3).

In the case that tax evasion is suspected, or there are losses or tax credits brought forward from previous tax years that require the tax auditors to verify such information, the comprehensive audit can be extended to five years backwards (N-5) with prior approval from the Minister of Economy and Finance.

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Documents required for a tax audit

The primary documents that are required for onsite tax audit include:

1. Enterprise information

• Management structure
• Certificate of Registration
• Certificate of Registration of VAT
• Articles of Incorporation
• Other business certificates from authorities, such as the Council for the Development of Cambodia and Ministry of Tourism

1. Accounting documents

• Financial statements
• Detailed list of each account of assets, owners’ equity and liabilities
• Detailed list of each account of income statement (profit/loss)
• Original voucher of documents such as:
  • Monthly payroll
  • Employment contract of foreign staff and managers
  • Lease or sale contracts
  • Bidding contract, if any
  • Monthly and annual tax returns
  • Monthly purchase-sale journals
  • Table of adjusted tax calculation
  • Purchase and sale invoices

How often are companies audited?

Tax audits will not be conducted on each taxpayer each year; taxpayers are subjected to be audited based on criteria of risk analysis as selected by the tax authorities.

For taxpayers who obtain tax compliance status, the timeframe of being audited are as follows:

• Gold status companies are subject to one comprehensive tax audit every two years and will not need to undergo a limited audit or desk tax audit.
• Silver status companies are subject to one comprehensive tax audit every two years, a limited tax audit every year and no desk tax audit.

Can taxpayers request a delay of tax audit fieldwork?

Tax audit fieldwork will be conducted within 10 working days after taxpayers receive a Notice of Tax Audit. However, taxpayers can request a delay of up to 30 days based on a reasonable cause.

For an extension of less than 10 days, taxpayers may verbally request through a discussion with the tax auditor in charge.

For longer than 10 days up to 30 days, a written request is required.

Tax audit process

The General Department of Taxation (GDT) shall give a Notice of Tax Audit (NTA) to taxpayers or their representative about the tax audit, which contains the following:

• Taxpayers’ name, address, and tax identification number
• Date of proposed audit fieldwork
• Period to be audited
• Type of audit
• Names of tax audit officers
• A list of required documents

Auditors may visit the taxpayers’ business premises, review documents, discuss with taxpayers any potential tax issues found and request additional documents to verify.

Taxpayers shall provide the required documents within seven days following the request. If there is a failure to provide the documents, the tax auditor may reassess the taxes based on the available information and in accordance with law and regulations on taxation.

After completing an audit, a Notice of Tax Reassessment (NOTR) is issued. The NOTR, which will be sent to taxpayers or their representative, specifies the reassessed type of tax, the basis of the tax reassessment, additional tax and interest.

If the taxpayer agrees with the reassessed tax liabilities in the NOTR, the taxpayer can make the tax payment.

However, if the taxpayer disagrees with any part or the whole of the NOTR, the taxpayer has 30 days after receiving the NOTR to submit an objection letter to the GDT. Upon submitting the objection letter, the GDT has 60 days to respond to the objection letter. The previously assigned tax auditors will work with the taxpayers to resolve the dispute.

A second objection letter can be submitted within 30 days if the taxpayer still disagrees with the GDT’s decision. Auditors from the Litigation Law and Statistic Department will be assigned to work with the taxpayer on the second objection letter.

If the taxpayer still disagrees with the GDT’s second decision, the taxpayer can submit the objection letter to the Tax Arbitration Committee under the Ministry of Economy and Finance within 30 days.

If the taxpayer disagrees with the Tax Arbitration Committee’s decision, the taxpayer may go to court, but currently, no specific court deals with tax audit disputes and going to court is a rare case.

Conclusion

Three types of tax audits conducted in Cambodia are desk tax audit, limited tax audit and comprehensive tax audit. Each type of audit has its own statutory limitation and taxes subject to the audit. Additionally, since updated tax regulations on tax audit have imposed a stricter audit timeline and procedure, you should be aware of your company’s tax compliance status and readiness for future tax audit to avoid unnecessary tax penalties and interest.

If you have any concern about your company’s tax compliance status, dealing with tax audit case, or other tax-related matters, Acclime can advise you on all aspects of your tax compliance and assist with any GDT audit.