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  3. Tax Invoice or Commercial Invoice? Which One Your Business Must Issue in Cambodia

Tax Invoice or Commercial Invoice? Which One Your Business Must Issue in Cambodia

Under Prakas 723 (14 Aug 2019) Cambodia has two invoice types — the tax invoice and the commercial invoice — and which one you may issue depends on your taxpayer class and who your customer is. This is the decision, with the exact differences.

InKhmer.com TeamOctober 19, 20269 min readFinance

The mistake almost everyone makes

Search "invoice template Cambodia" and you get one layout with a VAT toggle. Fill in the blank, tick the box if you are VAT-registered, download. That is how invoicing works in most countries. It is not how it works in Cambodia.

Cambodia has two invoices, and which one your business may issue depends on two things: what class of taxpayer you are, and who your customer is. The rule comes from Prakas No. 723 MEF.Prk, issued 14 August 2019 and effective 1 January 2020, with the operational detail in GDT Instruction 3033 / Notification 3218 of 6 February 2020.

Getting this wrong is not a cosmetic problem. A small taxpayer who issues a tax invoice has issued a document they are not entitled to issue. A medium taxpayer who hands a tax-inclusive commercial invoice to a VAT-registered business has not given that business the document it needs to claim input VAT.

The two documents

Tax invoice (វិក្កយបត្រអាករ)Commercial invoice (វិក្កយបត្រ)
Who issues itMedium and large (self-assessment) taxpayersSmall taxpayers to everyone; medium/large to end users
Who receives itRegistered taxpayers (business to business)End users and non-registered customers
Supplier blockName, address, TINName, address, TIN
Buyer blockName, address, and buyer TINName and address — no buyer TIN
NumberingSequential, with invoice dateSequential, with invoice date
LinesDescription, quantity, priceDescription, quantity, price
TotalExclusive of taxes, then each tax on its own lineInclusive of all taxes
TaxesVAT, specific tax, public lighting tax, accommodation tax — shown separatelyNot itemised
SignatureSeller or buyerSeller

Source: Prakas No. 723 (14 August 2019) and Instruction 3033 / Notification 3218 (6 February 2020).

The two differences that matter most in daily use are the buyer TIN and the tax treatment of the total. A commercial invoice is a single all-in figure. A tax invoice breaks the taxes out, because the registered business receiving it needs that breakdown to claim input VAT.

Step one: what class of taxpayer are you?

Cambodia's taxpayer classes were revised by Prakas No. 009, dated 12 January 2021, effective 1 January 2021. The classes are set by annual turnover and by sector:

  • Small — agricultural KHR 250 million to 1,000 million; service or commercial KHR 250 million to 1,000 million; industrial KHR 250 million to 1,600 million.
  • Medium — agricultural KHR 1,000 million to 4,000 million; service or commercial KHR 1,000 million to 6,000 million; industrial KHR 1,600 million to 8,000 million.
  • Large — agricultural above KHR 4,000 million; service or commercial above KHR 6,000 million; industrial above KHR 8,000 million.

If you are not sure which class you are in, that is the first question to settle — with your accountant or the GDT — because it decides which document you may issue.

Step two: who is the customer?

  • Registered taxpayer (another business, with a TIN) — if you are medium or large, this is a tax invoice.
  • End user (a walk-in customer, a consumer, anyone without a TIN) — this is a commercial invoice, whoever you are.

A small taxpayer issues a commercial invoice to everyone, registered or not. That is the whole point of the class: small taxpayers are not in the VAT invoice system, so they issue the document they are allowed to issue.

The five mistakes to avoid

1. Putting a buyer TIN on a commercial invoice. It is not required, and asking a walk-in customer for one is a sign the document was produced from the wrong template.

2. Itemising VAT on a commercial invoice. A commercial invoice presents one total, inclusive of all taxes. Itemising tax lines on it makes it look like a tax invoice without being one.

3. Issuing a tax invoice to an end user when you are a small taxpayer. This is the most common error in downloaded templates. The class decides the document, not the size of the sale.

4. Skipping the Khmer language. Instruction 3033 / Notification 3218 requires Khmer on the invoice, and any foreign language must appear below the Khmer, per label — not beside it, not instead of it, not behind a language switch. A bilingual invoice has Khmer on top and the other language underneath, everywhere.

5. Forgetting the riel total. Under Notification 4908 GDT of 18 March 2019, registered self-assessment taxpayers must show the total amount payable — including VAT — in KHR. Line amounts may stay in dollars. You may convert at either the GDT's published monthly rate for the previous month, or a market rate that is not lower than the National Bank of Cambodia daily rate. On conversion, a remainder above 0.5 riel rounds up to 1 riel and below 0.5 rounds down.

What about numbering?

Tax invoice numbering is sequential and chronological, and VAT invoice sequences restart each tax year. Branches keep separate sequences. If you issue invoices from more than one location, you are running more than one series.

Records must be kept for 10 years by medium and large taxpayers and 3 years by small taxpayers, per Prakas 723.

Where 2026 changes things: CamInvoice

Cambodia's e-invoicing system, CamInvoice, soft-launched in December 2024. Business-to-government invoicing became mandatory for national government entities in 2025, and from 2026 business-to-business clearance becomes mandatory for selected taxpayers, chosen on risk, size and sector. An e-invoice under CamInvoice is a UBL XML document validated by the GDT platform — it is legally valid only once cleared there.

A PDF invoice is not a CamInvoice e-invoice. It is a separate thing, and it stays a separate thing. If you are selected for the 2026 mandate, you will need a CamInvoice-capable channel in addition to whatever you use to produce everyday documents. The Cambodia Invoice Generator is a PDF document generator and says so plainly — it does not register you with CamInvoice and is not a submission channel.

Producing the right document

The decision is two questions: what class of taxpayer are you, and who is the customer. Everything else — the buyer TIN, the tax lines, the inclusive versus exclusive total — follows from those two answers.

The Cambodia Invoice Generator asks both questions, selects the tax-invoice or commercial-invoice variant, and shows only the fields that variant actually needs. It renders Khmer above English per label, computes VAT at 10% and, where they genuinely apply, public lighting tax at 5% and accommodation tax at 2% — the public lighting rate was raised from 3% by Prakas No. 168 of 20 March 2024, and several English-language summaries still carry the old figure. On a dollar invoice it stamps the riel total at the National Bank of Cambodia daily rate, with the rate and its bulletin date on the document. It is free, needs no account, and keeps nothing.

If you issue invoices continuously — with numbering sequences, a customer list, VAT returns and GDT reporting — that is a different job from producing one correct document, and khmerinvoice.com is the product built for it.

The short version

  • Two documents: tax invoice for registered customers of medium and large taxpayers; commercial invoice for everyone else.
  • Small taxpayers issue commercial invoices to everyone.
  • Buyer TIN only on a tax invoice.
  • Taxes itemised only on a tax invoice; the commercial invoice total is inclusive.
  • Khmer is required, with any other language below it.
  • Registered self-assessment taxpayers show the total in riel (Notification 4908, 18 March 2019).
  • VAT invoice numbering restarts each tax year; branches keep separate sequences.

This article is an explanation of the rules, not tax advice. Confirm your own position with the General Department of Taxation or a qualified adviser.

You Might Also Like

  • Create a Cambodia invoice — tax or commercial, in Khmer
  • What has to be on a Cambodian invoice: the Prakas 723 field checklist
  • Why your invoice total must be in riel
  • Quotation, invoice, receipt: which document at which point in the sale

Cambodia Invoice Generator

Pick your taxpayer profile and customer type — the tool selects the tax-invoice or commercial-invoice variant and renders it Khmer-first.

Create an invoice

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