柬埔寨：税收支出评估路线图

CAMBODIA A Roadmap for Tax Expenditure Assessment January2026 Prepared ByArtur Swistak, Mansoo Kim, Ross Warwick and Marius van Oordt ©2026 International Monetary Fund [HLS/017/26] High-LevelSummary Technical Assistance ReportFiscal Affairs Department CAMBODIA—A Roadmap for Tax Expenditure AssessmentPrepared by Artur Swistak, Mansoo Kim, Ross Warwick and Marius van Oordt TheHigh-LevelSummary Technical Assistance Reportseries provides high-level summaries of theassistance provided to IMF capacity development recipients, describing the high-level objectives,findings, and recommendations. ABSTRACT:This technical assistance report responds to Cambodia’s Ministry of Economy and Financerequest to support the development of a comprehensive framework for assessing tax expenditures. Thereport finds that Cambodia’s tax expenditures are widespread, costly, and largely unreported, withpreliminary estimates pointing to sizeable fiscal cost. The assessment covers four major taxes—PersonalIncome Tax, Business Income Tax, Value Added Tax, and Specific Taxes (excises)—and recommendsestablishing clear benchmark tax systems, improving data quality, and institutionalizing regular taxexpenditure reporting integrated into the budget process. The report emphasizes prioritizing capacitybuilding, developing microsimulation models, and focusing evaluation efforts on the costliest taxexpenditures to enhance transparency, fiscal discipline, and revenue mobilization. JEL Classification Numbers H72 (consulthttps://www.aeaweb.org/econlit/jelCodes.php)Keywords: Tax Expenditure; Tax Policy This technical assistance (TA) was provided with financial support from the Government of Japan. The contents of this document constitute a high-level summary of technical advice provided by the staff ofthe International Monetary Fund (IMF) to the authorities of Cambodia (the "CD recipient") in response totheir request for capacity development. Unless the CD recipient specifically objects within 30 businessdays of its transmittal, the IMF will publish this high-level summary on IMF.org (seeStaff OperationalGuidance on the Dissemination of Capacity Development Information). Background Cambodia has embarked on a medium-term Revenue Mobilization Strategy (RMS) aiming to increase taxrevenue from 12.5 percent of GDP in 2024 to at least 14 percent by 2028. Recognizing the significanterosion of the tax base by various tax expenditures, especially investment incentives, the governmentisprioritizingimproving transparency and management of these tax reliefs. The Ministry of Economy andFinance (MEF) requested technical assistance from the International Monetary Fund’s Fiscal AffairsDepartment to support the design and implementation of a structured Tax Expenditure Assessment (TEA)framework. The mission, conducted in late 2025, focused on assisting Cambodia in defining benchmark tax systems,identifying and costing tax expenditures, and preparing for the inaugural Tax Expenditure Report. Thisinitiative builds on prior efforts, including a preliminary 2025 Tax Expenditure Study by theauthorities’TaxExpenditure Working Group, and aligns with ongoing Public Financial Management (PFM) reforms andinternational best practices. The project is critical for enhancing fiscal transparency, informingtax policyreforms, and supporting the RMS objectives. Summary of Findings The technical assistance mission found that Cambodia’s tax expenditures are extensive, complex, andimpose a significant burden on the taxsystem.Thesetax expenditures arise from a diverse array ofstatutory tax reliefs embedded in the Law on Taxation, investment tax incentives under the Law onInvestment,anddiscretionarytaxconcessions granted by various authorities,includingcontractualarrangements. The most significant fiscal costs stem from specific (excise) taxes, particularlytaxexpenditures onfuel, followed by VAT exemptions and business income tax holidays, mainly for QualifiedInvestment Projects (QIPs). Personal income tax expenditures are less well quantified due to datalimitations butmay not be insignificantgiven the fragmentedpersonal incometaxframework. The mission emphasized the absence of clearly defined benchmark tax systems for the major taxes,which hampers consistent identification and costing of tax expenditures. For personal income tax, aconceptual dual income tax benchmark separating labor and capital income is recommended. Forbusiness income tax, a broad-based profit tax benchmark with a uniform 20 percent rate is advised. TheVAT benchmark should be a single-rate tax on all domestic consumption with specified exemptionsconsistent with international norms. For specific taxes, a benchmark based on taxing domestic socialcosts at categorical rates reflecting the higher of weighted average effective and modal statutory rates isproposed. Data quality and availability were identified as key constraints, particularly the need for improved accessto microdata from tax returns. The mission