Singapore–Cambodia Double Taxation Agreement: Second Protocol

Entry into force

The Second Protocol amending the agreement between the Government of the Republic of Singapore and the Royal Government of Cambodia for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income entered into force on 6 March 2026. The underlying double taxation agreement was signed on 2 November 2023 (IRAS, 6 March 2026).

What the protocol changes

The protocol amends the preamble of the double taxation agreement and introduces a new Article 28, “Entitlement of Benefits.” IRAS describes these changes as incorporating internationally agreed Base Erosion and Profit Shifting standards for countering treaty abuse, together with other technical amendments (IRAS, 6 March 2026).

This is a treaty update, not a general change to Singapore's domestic tax rates. The protocol should therefore be read together with the text of the Singapore–Cambodia agreement and the protocol itself when determining whether a particular cross-border income item qualifies for treaty treatment. IRAS provides the full protocol text from the release (IRAS, full protocol text).

Practical scope

The relevant population is persons and businesses whose income or tax position engages both Singapore and Cambodia; the release does not state a universal tax-rate change or a new monetary threshold. Any claim for treaty relief remains dependent on the applicable treaty provisions and the taxpayer's facts. For Singapore's wider tax structure and its network of international tax agreements, see taxation system.

Source note

This article records the treaty status announced by IRAS and the Ministry of Finance as at 6 March 2026. It does not substitute for professional advice or a determination by the competent tax authorities.