Singapore Cambodia Double Taxation Agreement Protocol Enters Force

The Second Protocol amending the Double Taxation Agreement (DTA) between Singapore and Cambodia, signed on November 2, 2023, is now in force as of March 6, 2026. Key changes include amendments to the DTA's preamble and the introduction of a new Article 28, "Entitlement of Benefits." These amendments aim to incorporate international standards for combating Base Erosion and Profit Shifting (BEPS) and prevent treaty abuse, alongside other technical adjustments.

This development is significant for businesses operating between Singapore and Cambodia, as it modifies the tax treaty framework. Compliance officers should review the full text of the Second Protocol to understand its implications on cross-border transactions, profit allocation, and the eligibility for treaty benefits. While the protocol is now in force, specific compliance actions may depend on how entities structure their operations and the nature of their income flows between the two jurisdictions.