EuroCham's Tax Forum 2026: The Real Reform Fight Is Over Who's Outside the Tax System

More than 150 tax officials, business leaders, and legal practitioners spent a day in Phnom Penh in late June discussing Cambodia’s tax system, and the loudest theme wasn’t a new levy or a rate change — it was the size of the economy sitting entirely outside the tax net. EuroCham Cambodia’s Tax Forum 2026, held at the Sofitel Phnom Penh Phokeethra on June 25 and formally handed its annual White Book 2027 to the General Department of Taxation (GDT) that day, put economy formalisation at the centre of the programme, ahead of the capital gains tax, DTA network, and compliance-certification sessions that followed it [S-826] [S-827]. For anyone running a company, holding property through a Cambodian entity, or planning to, the forum is worth reading past the press release — not because anything changed on June 25, but because it maps where the pressure points in Cambodian tax administration actually sit.

The number nobody quite agrees on

The informal economy is Cambodia’s central, unresolved tax-policy problem, and the disagreement over its size tells you almost as much as the size itself. Officially, Prime Minister Hun Manet has put the informal sector at more than 26.4 percent of GDP, with 97 percent of the country’s micro, small and medium enterprises operating informally [S-830]. An independent estimate from World Economics puts Cambodia’s shadow economy closer to 45.5 percent of GDP — nearly double the government figure [S-831]. Both numbers describe the same country; the gap between them is a function of how hard informal activity is to measure at all, not a rounding error. Either way, the practical conclusion is the same: a very large share of Cambodian economic activity generates no tax revenue, has no audited books, and operates without the compliance costs that formal businesses — including most foreign-owned companies and land-holding structures — carry as a matter of course.

The government is not ignoring this. Cambodia has rolled out a digital registration platform to simplify legal status for informal workers and businesses, expanded vocational training, broadened social-security coverage, and encouraged banks and microfinance institutions to extend credit to newly-formalised operators, with mobile registration units and SMS/QR-based outreach campaigns planned to reach remote areas [S-830]. These are real initiatives, not slogans — but they are also multi-year, low-and-slow programmes rather than a switch that flips the informal sector into the tax base.

Strengthen the formal sector first — not force the informal one in

The forum’s most useful framing came from EuroCham’s own leadership, and it cuts against the instinct to treat formalisation as an enforcement problem. Martin Brisson, EuroCham Cambodia’s Executive Director, argued explicitly against expecting informal businesses to comply overnight: “The real challenge is to create the conditions for formal businesses to grow, invest, and create quality jobs. As the formal economy expands, it can gradually absorb workers and entrepreneurs who currently operate informally… strengthening the competitiveness of the formal sector is not separate from addressing informality — it is one of the most effective ways of doing so” [S-826]. In other words, the chamber’s own house is the lever: make formal compliance cheaper and more predictable, and informality shrinks as a side effect, rather than trying to police it directly. This is a genuinely different theory of the problem than a crackdown, and it reframes several of the forum’s other sessions as pieces of that same strategy — not separate technical fixes.

The concrete complaint: a turnover tax that punishes thin margins

Underneath the formalisation framing sat a specific, quantifiable grievance. EuroCham used the forum to press its case against Cambodia’s 1 percent prepayment tax on turnover — the same mechanism this site’s own tax guide has already flagged as a floor that “punishes sloppy books” and squeezes thin-margin businesses regardless of whether they actually turn a profit [S-827]. The chamber’s ask is specific: recalculate the levy on a profit basis rather than gross sales volume, so that a business with high revenue and thin margins — construction subcontractors, low-margin retail, parts of the property-services sector — isn’t taxed as if it were as profitable as a high-margin business with identical turnover [S-827]. This is not a new demand invented for the forum; it is a long-standing structural complaint about Cambodia’s minimum-tax design, and the fact that EuroCham escalated it through the formal White Book channel signals it remains unresolved rather than quietly fixed.

Linda Oum, Vice-Chair of EuroCham’s Tax Committee and Tax Manager at Heineken Cambodia, captured the tension running through the whole day: Cambodia’s tax system has modernised meaningfully through digitalisation and closer alignment with international standards, but that same modernisation “simultaneously raises compliance expectations and audit scrutiny” [S-827]. Progress and pressure are arriving together — a fair characterisation of Cambodian tax administration generally, not just this forum.

Four technical sessions, one underlying theme: predictability

The afternoon’s breakout sessions covered ground this site has already mapped in depth, but each one is a live policy conversation, not settled law:

• Capital gains tax. A session with Bun & Associates, the GDT, DFDL, Knight Frank Cambodia, and EuroCham’s Real Estate and Construction Committee dug into the practical implementation of Cambodia’s CGT framework for businesses and investors [S-826] — the same tax whose repeated deferrals (most recently to January 1, 2027) our capital gains tax deep-dive already tracks. A dedicated real-estate breakout at a tax forum is itself a signal that property-sector CGT questions remain live enough to need expert clarification, not a settled rulebook.
• The DTA network. Dr. Antoine Fontaine of EuroCham and ANANT Law Firm led a session on Cambodia’s double-taxation agreement network with Compliance Partner’s Tiv Dina, who offered the forum’s cleanest soundbite: “A Double Taxation Agreement is not just a treaty, but a bridge that connects countries, encourages investment, and provides certainty for business operations across borders” [S-826]. That “bridge” is still narrow — our holding-company structures guide covers the current, limited DTA partner list, and this site’s Brazil coverage shows a major prospective trade partner still outside it. Expect DTA expansion to stay a standing agenda item at every future forum until the network catches up with where investment is actually coming from.
• Gold Taxpayer Status. GDT officials briefed the forum on this compliance certification, formalised under a 2016 regulation (Prakas 1536) that scores taxpayers Gold, Silver, or Bronze on filing and payment history [S-829]. Gold status — 16 to 20 points — earns a two-year compliance certificate, exemption from VAT audits, and eased access to VAT refunds on claims below roughly KHR 500 million (about $125,000) [S-829]. This is not abstract policy: for a property developer, land-holding company, or management firm with genuinely clean books, pursuing Gold status is a concrete, actionable way to cut audit friction — the forum’s inclusion of it signals the GDT wants more companies to actually apply, not just know it exists.
• Director salaries and shareholder premiums. A session aimed squarely at multinationals structuring how principals pay themselves out of a Cambodian entity — directly relevant to anyone running a company or holding structure here rather than drawing income personally.

The urgency underneath all of it: 2029

None of this is happening in a vacuum. EuroCham’s White Book 2027 — handed to the GDT at this same forum — explicitly frames faster tax, trade, energy, and digital reform against Cambodia’s scheduled 2029 graduation from Least Developed Country (LDC) status [S-828], the same deadline this site’s industrial-parks and SEZ analysis has already flagged as a structural turning point for trade preferences. Losing LDC status means losing preferential market access that has underwritten much of Cambodia’s export growth; the tax system’s credibility and predictability become part of what has to replace those preferences as a reason for investors to stay. A forum debating turnover-tax fairness and DTA coverage in 2026 is, underneath the technical detail, rehearsing for a 2029 competitiveness problem that has nothing to do with tax administration per se.

Reading the forum honestly

A EuroCham forum is advocacy and dialogue, not legislation. Nothing announced on June 25 changed Cambodian law. The White Book is a wish list handed to the GDT, not a commitment from it; the 1 percent prepayment tax has not been recalculated; no CGT implementation date has moved; the DTA network has not grown. What the forum actually demonstrates is where the pressure is concentrated — informality, turnover-tax fairness, CGT clarity, DTA coverage, and compliance certification — and that the same handful of issues keep resurfacing across EuroCham’s public-private dialogues rather than getting resolved. That pattern is itself useful information: it tells you which parts of Cambodia’s tax framework to treat as unsettled and worth checking current guidance on, rather than assuming last year’s answer still holds.

What it means for property and business investors

• Don’t assume Cambodia’s tax rules are static. CGT implementation, DTA coverage, and the turnover-tax base are all live debates, not finished policy — verify current guidance before structuring around any of them.
• Consider Gold Taxpayer Status if you run a Cambodian entity with clean compliance history — it is a real, obtainable reduction in audit exposure, not a theoretical benefit.
• Check DTA coverage for your specific home jurisdiction before assuming relief exists. The network is real but narrower than investors from outside Asia often expect.
• If you operate a thin-margin business (construction subcontracting, low-margin retail, some property-services models), watch the prepayment/ minimum-tax debate — it directly affects your effective tax floor regardless of profitability.
• Treat 2029 as a real deadline, not a distant one, when evaluating multi-year holdings or business plans — the reform pressure this forum reflects is timed against it.

The takeaway

EuroCham’s Tax Forum 2026 didn’t produce a new tax law, and it wasn’t meant to — it produced a clear map of where Cambodia’s tax framework remains unsettled: an informal economy the government and independent estimates can’t agree on the size of, a turnover tax the business community says punishes thin margins, a capital gains regime still being clarified sector by sector, a DTA network narrower than the investment flows it needs to support, and a compliance-certification system most eligible companies still haven’t used. Underneath all of it sits a 2029 deadline that turns “get the tax system right” from a nice-to-have into a competitiveness requirement. None of this is investment advice, and none of it is settled — treat the forum as a preview of where Cambodian tax policy is heading, verify the current rules before you rely on them, and expect most of these same issues to resurface at next year’s forum.

Sources

• [S-826] Cambodia Investment Review — EuroCham Cambodia Tax Forum 2026 Focuses on Economy Formalisation and Investor-Focused Tax Reforms — forum details, speakers, White Book 2027 handover, Martin Brisson/Linda Oum quotes, CGT/DTA/Gold Taxpayer/director-salary breakout sessions, Tiv Dina DTA quote.
• [S-827] Cambodge Mag — EuroCham Tax Forum: Cambodia Seeks to Shed Its Fiscal Ambiguity — June 25, 2026 date; 150+ attendees; 1% prepayment tax criticism and profit-basis recalculation ask; Linda Oum quote on compliance expectations and audit scrutiny; 2029 LDC urgency framing.
• [S-828] Cambodia Investment Review — EuroCham White Book 2027 Calls for Faster Tax, Trade, Energy and Digital Reforms Ahead of Cambodia’s 2029 LDC Graduation — White Book 2027’s four reform pillars; 2029 LDC graduation context.
• [S-829] DFDL — Benefits of Tax Compliance Certificates — Gold/Silver/Bronze compliance framework under Prakas 1536 MEF (Dec 2016); Gold status scoring, two-year certificate, VAT audit exemption, VAT refund access under ~$125,000.
• [S-830] Khmer Times — Informal economy and the making of a confident Cambodia — PM Hun Manet’s 26.4%-of-GDP informal economy figure; 97% of MSMEs operating informally; government digital-registration and mobile-outreach formalisation initiatives.
• [S-831] World Economics — Cambodia’s Informal Economy — independent shadow-economy estimate of approximately 45.5% of GDP.