Tax & Transfer Pricing Advisor

Tax & Transfer Pricing Advisor — DFDL Cambodia, Daun Penh, Phnom Penh

DFDL Cambodia is seeking an experienced Tax & Transfer Pricing Advisor for its Phnom Penh office. You will advise multinational enterprises, investors, and financial institutions on Cambodian tax compliance, transfer pricing documentation, and tax-efficient investment structures under the Law on Taxation (amended 2023) and the Transfer Pricing Prakas (2017).

Cambodia's tax regime is evolving rapidly, with increased scrutiny from the General Department of Taxation on transfer pricing and international tax structures. This role is ideal for a tax professional seeking to shape compliance strategies in a dynamic market.

• Advise on corporate income tax, withholding tax, VAT, and specific tax compliance for Cambodian entities
• Prepare transfer pricing documentation, benchmarking studies, and local file reports
• Advise on tax incentives for QIPs, SEZ entities, and priority sectors
• Represent clients during tax audits and disputes with the General Department of Taxation
• Structure cross-border transactions to optimise tax efficiency within Cambodia's treaty network
• Monitor legislative developments and advise clients on forthcoming tax reforms

• 7-10 years' experience in tax law, transfer pricing, or tax advisory
• Degree in Law, Accounting, or Taxation; CPA or BAKC membership preferred
• Expert knowledge of the Law on Taxation, transfer pricing Prakas, and double taxation agreements signed by Cambodia
• Experience preparing transfer pricing documentation and conducting functional analyses
• Familiarity with OECD Transfer Pricing Guidelines and their application in Cambodia
• Fluent English and Khmer