Scholarly Articles

Cambodia’s Law on Taxation[1] featured a definition of “permanent establishment” (the Cambodian PE) from its first draft in 1997. The Cambodian PE functions much like in other countries as a source nexus for the Cambodian income taxation of business income derived from Cambodia by non-residents. Income from business activities by a non-resident taxpayer are only […]
Aug 04, 2024
Since April 2022, born from the COVID boom of online business, a new and costly tax system was created in Cambodia to hit a very wide range of cross border transactions. Although taxpayers are supposed to implement this already for nearly 2 years, misunderstandings about the scope of the VAT Reverse Charge are widespread. In […]
Feb 26, 2024
Tax treaties between industrialized countries and developing countries presently take up the majority of the world’s bilateral income tax treaties. Many of these tax treaties were concluded at a time when the developing country found itself in a less than desirable negotiating position. This article analyzes the considerations in determining the feasibility of a developing […]
Aug 01, 2022
This is the eight and last part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132 from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”).
Feb 06, 2020
This is the seventh part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132 from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”).
Feb 06, 2020
This is the sixt part in a series of contributions focused on analyzing Vietnam’s current key transfer pricing regulation Decree 132 from the perspective of the 2022 Transfer Pricing Guidelines (“TPG”) of the Organization for Economic Cooperation and Development (“OECD”).
Feb 06, 2020
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Edwin Vanderbruggen
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