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Dec 14, 2015

Notification No. 9737 On the Extension of the Deadline for Updating Company Information, Managed Under The Department of Large Taxpayers

By Simon Burlinson

In an encouraging move by the General Department of Taxation (“GDT”), it has recently issued Notification No. 9737 (20 November 2015) informing all companies and enterprises under the authority or management of the Department of Large Taxpayers which had registered with the GDT prior to 1 November 2014, that they now have until 31 December 2015 to re-register.

The GDT had previously set a deadline of 15 November 2015 for companies to update their tax registration (by issuing Notification No. 7487 on 23 September 2015).  However, it appears that many companies could not meet that deadline, hence the grant of this extension.

The grant of an extension for companies to update their tax registration is a welcome indication that the GDT is listening to the concerns of the private sector and taking action as a result.  Indeed, the GDT appears to recognize the logistical issue created by the requirement for a company’s duly authorized foreign officer to physically present themselves at the GDT to have their photographs and thumbprints taken.  While this may not be the sole reason for the current extension, it has certainly been a major issue for many foreign-owned companies who will no doubt welcome this decision of the GDT.

Unfortunately, as previously stated in Notification 7487, the recent Notification 9737 reiterates some of the harsh penalties that can be applied for companies’ failure to meet the deadline of 31 December 2015.  These include (amongst others permitted by relevant law):

  1. Invalidation of a company’s VAT certificate;
  2. Refusal of requests for input tax credits or VAT refunds;
  3. Liaison with the General Department of Customs and Excise to cease a company’s import/export activities; and
  4. Liaison with the Council for the Development of Cambodia to delay a company’s request to import raw materials and equipment.

Hopefully this further extension is sufficient for applicable companies to comply with the requirement to re-register with the GDT, although, given the fact that Christmas is around the corner, the ability of a company’s authorized officer who lives abroad to come to Cambodia to present at the GDT during this festive season might be a legitimate cause for doubt.

Sciaroni & Associates Taxation Practice Group offers a full range of tax advisory and tax compliance services to local and international businesses. To our local clients we bring international standards of professional service and to our international clients we merge our understanding of local compliance and legislative practices with quality of service

Sciaroni & Associates is a leading professional services and investment advisory firm that has been doing business in Southeast Asia since 1993.  Based in   Cambodia with legal offices in  Laos and Myanmar, we provide knowledgeable business insights and experienced guidance to many of the world’s leading companies, financial institutions, governments and international organizations to help maximize the value of their investments.

For more information please visit www.sa-asia.com or contact us at info@sa-asia.com.

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Sciaroni & Associates is a leading professional and investment advisory firm doing business in Southeast Asia since 1993. Based in Cambodia with legal offices in Laos and Myanmar, we provide experienced advice and business insights to many of the world’s leading companies, governments, economic think tanks, global development funds, international NGOs and the Royal Government of Cambodia in accordance with strict international standards.
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Street Address: No. 24, Street 462, Sangkat Tonle BassacKhan Chamkarmon, Phnom Penh, Cambodia
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