On 29 July 2026, the Ministry of Economy and Finance issued Prakas No. 584 on Tax Debt Liability for Business Transfer, Share Transfer, or Enterprise Merger (“Prakas 584”). The Prakas provides much-anticipated guidance on how tax liabilities are allocated between transferors, transferees, shareholders and surviving entities when businesses, shares or enterprises change hands in Cambodia.
Prior to the issuance of Prakas 584, the only reference on the assumption of tax liabilities in such transactions was Article 215 of the Law on Taxation (“LOT”), which introduced the principle that tax debt obligations may pass to new owners, shareholders, or surviving enterprises in business transfers, share transfers, or enterprise mergers. Article 215, however, provided only a broad framework, without specifying how those liabilities would be allocated in practice.
Prakas 584 fills that gap by setting out detailed rules on successor liability, notification requirements, value-added tax (“VAT”) treatment for business transfer, and the circumstances in which historical tax debts may transfer to new owners, shareholders, or surviving entities.
For further information on the tax update, please visit DFDL.
