柬埔寨国家通行自由外汇制度,本国货币称为瑞尔, 1 美元约兑换4000 瑞尔,但同时流通美元,商店均以美金和瑞尔计价。
2003年,柬埔寨以发展中国家身份进入 WTO ,在柬投资设厂者从 WTO 会员国进出口享有优惠关税,另外美、日十大彩票网络平台、欧盟等国还给予柬埔寨 GSP 优惠关税及免配额优惠。
2016 年劳工部规定人员最低工资为每人每月 140 美元,人力成 本低廉;青壮年在人口比例中占比很高,人口红利优势显著十大彩票网络平台。
1. Investment Incentives Granted to a Qualified Investment Project (QIP)
QIPs are entitled to the following investment incentives (“Amended Law on Investment”):
·? QIPs may elect to receive a profit tax exemption or use speci al depreciation.
·? Profit tax exemption (Selective): A tax holiday period is composed of “Trigger period” + 3 years + Priority Period (Maximum total 9 years)
– Maximum Trigger Period: commencing on the issuance of the Final Registration Certificate and ending on the last day of the taxation year immediately preceding the earlier of:
(a)if the QIP derives a profit, the taxation year that the profit is first derived; and
(b)if the QIP derives income from the Investment Activity in respect of the sale of goods or?services, the third taxation year after the taxation year in which the income is first derived.
– Priority Period: To be determined by the Financial Management Law, within the period of 3 years, according to the type of project and investment capital (For light industries: 0 year in case of investment capital of below US$ 5 million, 1 year in case of investment capital between US$5 million and 20 million, 2 years in case of investment capital over US$ 20 million)
·? An annual Certificate of Obligation Satisfaction (or “Certificate of Compliance”) has to be obtained by the QIP to be entitled “Profit Tax Exemption”.
·? A QIP shall be subject to a profit tax rate after its tax exemption period as determined in the Law on Taxation
·? Special depreciation (Selective): 40% special depreciation allowance on the value of the new or used tangible properties used in the production or processing.
·? Duty free import of production equipment, construction materials, etc. as shown in the following table.
·? A QIP located in a designated SPZ or EPZ: To be entitled to the same incentives and privileges as other QIP stipulated in the Amendment to the LOI.
·? A QIP shall be entitled to 100% exemption of export tax, except for activities as stipulated in laws in effect.
·? The rights, privileges and entitlements of a QIP can be transferred or assigned to a person who has acquired or merged a QIP subject to the approval of the CDC or PMIS.
Projects not Eligible for the Incentives
The investment projects listed in Section 2 (Investment Activities Not Eligible for Incentives) of Annex 1 of the Sub-Decree No.111 are not eligible for investment incentives. Those investment projects include the following:
·? All kinds of commercial activity, import, export, wholesale, and retails, including duty free shops
·? Any transportation services by waterway, by road, by air except investment in the railway sector
·? Restaurants, karaoke parlors, bars, nightclubs, massage parlor, fitness, etc.
·? Tourism service
·? Casino and gambling business
·? Currency and financial business and services such as banks, financial institutions, and insurance companies
·? Activities related to newspaper and media, including radio, television, press, magazine, etc.
·? Professional services
·? Production and processing of wood products using wood from natural forest with a legal domestic supply source for raw materials
·? Complex resort, including hotel, theme park, sport facilities, zoo with less than 50 hectares
·? Hotel below 3-star grade
·? Real estate development, warehouses facilities
Projects Eligible for the Incentives
Section 2 of Annex 1 of the Sub-Decree No.111 also sets the minimum amount or other conditions of investment projects in various fields, which are required for granting the incentives. Some of those requirements are shown in the following table.
2. Investment Incentives Granted to a Project in SEZ (Chapter 4, the SEZ Sub-Decree)
The SEZ Sub-Decree sets forth that the CSEZB shall examine and provide incentives to all the SEZs and that all the incentives shall be specified in the FRC.
As the Law on Amendment to the Law on Investment of 2003 defines in Article 14.9, a QIP located in a designated Special Promotion Zone (SPZ) or Export Processing Zone (EPZ) is entitled to the same incentives and privileges as other QIPs stipulated in the Law. The incentives to be granted to the Zone Developers and Zone Investors are summarized below in the following table.
3. Incentives Entitled to Specific Fields?
Despite the provisions regarding the investment incentives for QIPs under Chapter 5 of the Amended Law on Investment, the industry-specific or additional incentives have been introduced by the RGC in forms of Prakas or other regulations.
·?Import duty reduction or exemption and the government-borne VAT scheme (VAT exemption) have been introduced on various agricultural materials such seeds, breeds or residues and agricultural machines including tractors. : Prakas No.390 (MEF) on Adjustment to Customs Duty and Imposition of VAT borne by the State.
·?QIPs in the area of agriculture and agro-industry may obtain incentives in the form of a priority period of tax exemption on profit for three (3) years. Investment activities in the area of agriculture and agro-industry shall receive such incentives according to the Sub-Decree relating to the Implementation of the Law on Investment. : Royal Kram NS/RKM/0609/009 on Promulgation of the Law on the Adjustment to the Law on Financial Management for the Year 2009 of June 20, 2009
·?VAT on the imported production input by garment factories is exempted as long as the final products are exported. The Letter No.110 SCN.CS of the Council of Ministers of January 27, 1999
·?VAT on the imported production input and equipment of supporting industry, who serves to the export of garment, textile or footwear, shall be exempted. The supply of the products or services for the export of the garment by the supporting industry or contractor shall be exempted. : Prakas No.298 (MEF) on the Implementation of VAT for Supporting Industry or Contractor who Supplies Products for the Exports of Garment, Textile and Footwear.