GDT e-VAT compliance checklist for Cambodia SMBs

How to use this checklist

Work through each of the 25 items below. Award yourself one point for every item you can answer 'yes' to with confidence, not 'mostly' or 'we think so'. At the end, total your score. Use the scoring guide at the bottom to interpret where you stand. This checklist is useful in three situations: before a GDT audit (to close gaps before you are asked); before selecting an accounting or ERP vendor (to brief them on what compliance actually requires); and as a periodic internal review: run it quarterly, or any time your entity structure, software, or banking arrangements change. If you are running it before choosing a system rather than after, our ERP in Cambodia guide covers the wider platform decision these items feed into. It is not a legal opinion. It is a structured prompt to surface the gaps that cost Cambodia SMBs time and money when they surface at the wrong moment.

Registration and legal foundation (5 points)

This section confirms that the legal and registration scaffolding is current. An inactive TIN or an expired business license invalidates everything else you do.

1. VAT registration is current, and you know which side of the registration trigger you sit on: taxable turnover over KHR 125 million on goods or KHR 60 million on services across three consecutive months, or a government contract over KHR 30 million. Voluntary registration counts, and the registration certificate is on file.
2. The GDT-issued TIN is active, matches the name and address on the business license, and can be successfully used to log in to the e-Tax portal today.
3. The business license (Ministry of Commerce registration) is current, not expired, and reflects the current registered address and directors.
4. Shareholder and director records held at the Ministry of Commerce are up to date: no changes in the last 12 months that have not been formally notified.
5. e-Tax portal credentials (username and password) are known, stored securely, and have been tested within the last 90 days, not held only by one person who may have left.

Books, charts, and journals (5 points)

Cambodian entities report under CIFRS (or CIFRS for SMEs) and keep their books under the Law on Accounting and Auditing. GDT expects books that tie to filed returns line by line, whatever numbering scheme the chart uses.

6. The chart of accounts is built for Cambodian reporting, not left on a generic QuickBooks or Xero default. Key accounts (output VAT, input VAT credit, WHT payable by rate, salary tax payable) exist as distinct ledger lines that reconcile to the corresponding line on the monthly return.
7. Dual-currency books (KHR and USD) are maintained with a declared functional currency. KHR amounts are not derived by rounding USD at the filing stage; they are posted at transaction time using the NBC official exchange rate for that date.
8. Month-end close is completed within 25 calendar days of each month end, which allows enough time to prepare and file the monthly VAT return by the GDT deadline of the 25th of the following month.
9. Every journal entry has an audit trail: a reference to the source document (invoice number, bank statement line, purchase order) that supports the posting. The trial balance can be reconciled to the VAT return without reconstructing entries from memory.
10. Financial records are retained for at least ten years from creation in a format that allows reconstruction of the original journal entries, as required by Article 23 of the Law on Accounting and Auditing 2016. Records stored only on a single staff member's laptop do not satisfy this requirement.

Invoice and sales compliance (5 points)

Invoice format and numbering is the most common GDT audit trigger for Cambodia SMBs. GDT expects sequential numbering, mandatory fields, and correct VAT calculation on every document.

11. Sales invoices carry a serial number in chronological order, restarting at 0001 each tax year, with no duplicates and no mid-year resets (Instruction No. 21606 GDT). Branch or office prefixes may identify a location but must not encode customer, product, or activity type. Gaps are not expressly prohibited but invite audit challenge, so numbering is coordinated centrally when invoices are raised from multiple systems or locations.
12. Customer TINs are captured for VAT-registered buyers. The TIN on the invoice matches what is held in GDT's registry for that buyer, not just what the customer told you verbally.
13. VAT is calculated correctly on every invoice line: 10% on standard-rated supplies, 0% on exported goods and services rendered outside Cambodia, exempt where applicable. The VAT category is applied per item, not assumed to be the same across all lines, and the exempt list is read correctly (unprocessed agricultural products are exempt; processed food is not).
14. The invoice format meets the Prakas No. 723 minimum fields: seller name, address and VAT TIN; invoice number in chronological order; date of issue; buyer name, address, and TIN (TIN required only where the buyer is a registered taxpayer); description, quantity, and selling price; the price excluding transactional taxes; each applicable tax shown separately (VAT, Public Lighting Tax, Specific Tax, Accommodation Tax); the total; and the supplier's name and signature. Invoices are in Khmer, or Khmer with English beneath, with amounts in KHR, and are issued within 7 days of shipment or of the service being rendered.
15. The business has assessed its readiness for CamInvoice e-invoicing, the GDDE's real-time B2G platform launched 12 May 2025. If the business bills government counterparties, CamInvoice integration is in scope now. See the CamInvoice integration guide for the integration requirements.

Tax filings and remittance (5 points)

Filing is only half the obligation. GDT also expects correct classification on every return type (VAT, withholding tax, and salary tax) and evidence that correspondence has been acknowledged.

16. Monthly VAT returns (VAT 01) are filed by the 25th of the following month for every period since registration. There are no missed periods and no amended returns outstanding that have not been resolved.
17. Withholding tax (WHT) is correctly classified per counterparty and payment type: 15% on services, royalties, and interest paid to residents, 10% on rental, 14% on payments to non-residents, with the exclusion for services billed by a registered taxpayer against a valid VAT invoice applied correctly. The classification is applied at the invoice level, not assumed to be the same for all suppliers.
18. Tax on Salary is calculated correctly, remitted monthly, and the monthly return is filed by the deadline. Payroll records reconcile to the filed amounts.
19. GDT correspondence (notices, queries, assessment letters) is on file and acknowledged. Any penalty or surcharge notices have been responded to within the GDT timeframe. Unanswered GDT correspondence is a high audit-risk signal.
20. A penalty and late-filing log exists: every late filing, additional-tax assessment, or unilateral assessment across the retention window is documented with the resolution and payment reference. This log is available to an external auditor on request.

Software and integration (5 points)

Software compliance is where most Cambodia SMBs score lowest. Spreadsheet-based workflows and off-the-shelf SaaS that has no GDT adapter create accumulating risk that surfaces only during an audit.

21. The accounting or ERP software in use supports the Cambodian chart of accounts, dual-currency (KHR/USD) posting, and produces GDT-compatible VAT and WHT output data, not a manual export that requires hand-formatting before filing.
22. The audit trail in the system is exportable: every journal entry, source document link, and VAT line can be exported in a structured format (CSV, PDF, or API) that an external auditor or GDT reviewer can read without vendor-specific software.
23. Multi-currency reconciliation is working correctly: KHR and USD balances reconcile at month-end without manual adjustments; invoices convert at the NBC daily official rate for the invoice date, and the monthly declaration converts at the NBC rate for the last day of the month, rather than at an estimated or averaged rate.
24. API or file-based submission to the GDT e-VAT portal is working for at least monthly VAT returns; the filing is not a manual copy-paste from a spreadsheet into the web portal each month. For the case for API integration, see how GDT e-VAT filing works.
25. An integration partner or internal team member has been identified who can extend the integration to cover CamInvoice real-time submission and any future GDT API changes; the system does not depend entirely on a single person whose availability is uncertain. See our API integration practice for what this engagement looks like.

What to do with your score

Add up your points. The scoring bands are: 0–10, at risk. You have material compliance gaps that a GDT audit would surface quickly. Prioritise registration and filing compliance first; those are the statutory obligations. Books and software gaps are serious but can be remediated over a quarter. 11–18, mostly compliant, but exposed. You likely have clean registration and filing history but gaps in audit trail depth, invoice format, or software integration. An audit is survivable but would require significant manual reconstruction. Use this score to identify which of the five sections scored lowest and work through those items first. 19–25, audit-ready. Your compliance posture is strong. The remaining gaps are likely in the software and CamInvoice readiness sections, which are forward-looking rather than historical. Plan a CamInvoice readiness review before the B2B mandate dates are published.

If you scored below 19 and want to close the gaps systematically, the most impactful areas to address first are: (1) software integration: moving from manual filing to API submission removes two to three staff-days per month and creates the audit trail automatically; (2) WHT classification: misclassification here generates penalty exposure that compounds over multiple periods. For software integration options, see our accounting system solutions. For API integration scope, see our API integration practice.

Frequently asked questions

How often should we run this checklist?

At minimum, once per year as part of your annual compliance review. Also run it before: any GDT audit notification; a change in accounting software or ERP; a change in entity structure (new shareholder, new director, new subsidiary); and before CamInvoice B2B mandate dates are announced.

Who should fill it out?

The finance manager and the external accountant (if you use one) should fill it out independently and then compare scores. Divergence between the two scores is itself a finding; it reveals where institutional knowledge is not documented.

What counts as a 'yes'?

A 'yes' means you can evidence the item today without preparation: you could show a GDT auditor the document, the system output, or the record within an hour. 'We do this in practice' without documentation is a 'no' for scoring purposes.

Can we rely on our accounting firm to handle all of this?

Your accounting firm handles filings. They do not control your invoice format, your software audit trail, your WHT counterparty classification, or your CamInvoice readiness. The checklist covers obligations that sit with you as the business, not exclusively with a third-party filing agent.

How do we select an integration partner for items 24 and 25?

Look for a partner who has completed at least one live GDT API integration and can show you a real filing output, not a demo. Ask specifically about WHT classification logic and multi-currency rounding. See how GDT e-VAT filing works for the questions to ask any integration partner.

Does this checklist cover CamInvoice as well as GDT e-VAT?

Item 15 (invoice compliance) and item 25 (integration partner) specifically address CamInvoice readiness. For a full CamInvoice integration assessment, use the CamInvoice integration guide; it covers the GDDE registration, adapter architecture, and go-live checklist in detail.

What if we have multiple legal entities?

Run the checklist separately for each legal entity. Each entity has its own TIN, its own filing obligations, and its own software setup. A group that scores 22 in one entity and 8 in another has the same audit risk as a group that scores 8 overall; the gaps in the weaker entity are the exposure point.