No tax treaty between France and Cambodia: French tax is paid without a tax credit for Cambodian tax.

France does not have a tax treaty with Cambodia: the country is not listed in the official BOFiP (French Official Tax Bulletin). For a French tax resident, income from Cambodian sources remains taxable in France, and tax paid in Cambodia does not entitle the holder to a tax credit. For an individual resident of Cambodia, a dividend from French sources is subject to a withholding tax of 12.80% (%), without any reduced treaty rate. This page deals with the French perspective. It does not provide any Cambodian tax rates: the country's tax regulations, published in versions labeled KH (Khmer), are not reproduced here.

What the official list of conventions says

The BOFiP publishes annex BOI-ANNX-000306, "List of tax treaties concluded by France", in force since 29/04/2026. The annex specifies that only agreements in force on 1 January 2026 are included. Cambodia is not included.

Cambodia's neighbors are distributed differently. The same analysis reveals a convention with Thailand (December 27, 1974) and one with Vietnam (February 10, 1993). Laos is not listed. The list makes no mention of any agreement signed but not yet in force at the reference date.

Cambodian income of a French resident: taxable in France, without tax credit

Establishing a residence in France is determined according to Article 4 B of the French General Tax Code (CGI). The French Tax Administration's Official Bulletin (BOFiP) lists three situations: having one's home or principal residence in France, carrying out a professional activity there, or having the center of one's economic interests there. Only one of these is required. Spending more than six months in France per year is not an absolute criterion. The BOFiP makes an exception for secondary activities.

The practical guide to income tax states: "In the absence of a tax treaty, income is taxable in France." It adds that without a treaty, France does not eliminate the possibility of double taxation. Treaties, on the other hand, prevent this through a tax credit or exemption, which is then factored into the effective tax rate.

For securities, the instructions for form 2047 (income tax return 2025) are more detailed. Income originating in a country without a tax treaty with France does not qualify for any tax credit. It must be declared net of foreign tax on lines 220 and 250. If no tax was paid locally, the gross amount is entered on form 2047.

This guide focuses on income from securities. Cambodian salaries, rent, or profits fall under other categories; this page does not cover them.

A French dividend paid to a natural person residing in Cambodia: a numerical example (fictitious profile)

Situation. Sophie, a fictional profile, is a natural person residing in Cambodia. She holds shares in a French company that pays her a gross dividend of €10,000 (hypothetical).

Issue. She wants to know what France is retaining, and if a reduced rate applies.

Strategy. She notes that France has no tax treaty with Cambodia. Dividends from French sources received by a non-resident individual are subject to a withholding tax of 12.80% (%), the rate in effect as of January 1, 2026, "subject to more favorable provisions under international tax treaties." No treaty is listed: no more favorable provision is cited here. The rate would be 75% (%) for income paid outside France in a non-cooperative state or territory; the list reproduced in the appendix to the 2027 Finance Bill does not mention Cambodia, which is confirmed as of the date of payment. Social security contributions do not apply to a non-resident on investment income.

Result. The French withholding tax is €1,280, and the net dividend is €8,720. Any additional tax Cambodia imposes on this dividend is not included here; it is not quantified.

What we know about Cambodian tax laws

The tax administration of Cambodia is the General Department of Taxation (GDT). Its website publishes laws, sub-decrees, prakas (ministerial orders), and circulars. Four key points are visible there:

The GDT lists them as valid; the download links are labeled KH (Khmer). This page provides no definition of residence, tax brackets, withholding tax, or capital gains tax rates. It doesn't mention any of them.

Cambodia has double taxation agreements with other countries. The GDT lists a law dated August 18, 2022, concerning agreements with Macau (China) and Turkey. These agreements do not apply to France.

Exchange of information: what the French lists show

The annex to the 2027 draft budget law concerning France's intelligence-sharing network contains a table of states with administrative assistance agreements in force as of September 1, 2026. Cambodia is not listed, and the word "Cambodia" does not appear anywhere in the document. The page does not draw any conclusions about the existence of such agreements; it merely notes the country's absence from the table.

The same document indicates that 11 states and territories are on the French list of non-cooperative states and territories, according to the decree of April 15, 2026 cited in the footnote: Anguilla, Antigua and Barbuda, Guam, the U.S. Virgin Islands, the Turks and Caicos Islands, Palau, Panama, Russia, American Samoa, Vanuatu, and Vietnam. The list reproduced in this appendix does not include Cambodia; the decree itself has not been reviewed, and the list is accurate as of the date of submission.

Accounts and contracts: Declaration 3916

If you are a French tax resident and have opened, used, or closed an account in Cambodia, form 3916 or 3916-bis must be added to your tax return each year. The tax authorities set the penalty at €1,500 per undeclared account. This penalty increases to €10,000 when the account is located in a country that does not have a tax treaty with France. The tax authorities' website does not specify what falls under this category. Therefore, the amount applicable to a Cambodian account is not provided here; it must be verified on the date of the tax return.

French income of a resident of Cambodia

If you are living in Cambodia, you are only taxed in France on your French-source income, subject to tax treaties. For income received in 2025, the tax rate cannot be less than 20% of the French tax rate (%) up to €29,579, nor less than 30% of the French tax rate (%) above that amount. The average tax rate is an option, if it is more advantageous for you: it requires declaring all household income, both French and foreign.

Dual residence: what this page does not address

When a tax treaty exists, a set of criteria determines dual residency: permanent home, closest personal and economic ties, habitual residence, and then nationality. In this case, no treaty exists, and the BOFiP (French Official Tax Bulletin) consulted does not explicitly address this situation. Therefore, the page does not explain how to determine dual residency between France and Cambodia, especially since the Cambodian residency criterion is not included.

What changes depending on your situation

• Your tax residence: France, Cambodia, or a situation in between.
• The nature of the income: dividend, interest, capital gain, salary, rent.
• The amount withheld at source and the date of payment.
• Accounts or contracts held in Cambodia must be declared in France.
• The date of your decision: the rates and the list of non-cooperative states are verified on this date.

The rule depends on your situation. No results are guaranteed.

What this page does not cover

It does not specify the criteria for tax residency in Cambodia, nor the Cambodian tax rates, local withholding taxes, wealth tax, inheritance tax, social security contributions, or visas and residence permits. Local tax matters should be verified with a Cambodian professional; French tax matters are addressed in our sections on tax domicile, the 2047 tax return, and form 3916.