On April 2, 2024, the Cambodian Competition Commission (CCC) issued Decision No. 087 on Requirements and Procedures of Exemptions under the Law on Competition, outlining the requirements and procedures for requesting exemptions for agreements or activities that could prevent, restrict, or distort competition in Cambodia. Franchise agreements often include clauses such as price fixing, exclusive supply arrangements, or territorial restrictions, which could potentially raise concerns under the Law on Competition. Therefore, it is necessary for both franchisors and franchisees to understand how the law applies to their agreements and whether an exemption request may be required. Some arrangements under franchise agreements may fall within the scope of prohibited practices under the Law on Competition. These include horizontal and vertical agreements, abuse of dominant position, and anti-competitive business combination. If a business owner contemplates that their franchise agreement could be interpreted as anti-competitive, they must assess whether to apply for an exemption. Key Criteria for Exemption Under Decision No. 087, the CCC may grant an exemption if the applicant can demonstrate that the proposed agreement or activity meets all four of the following conditions: Significant and identifiable benefits: The agreement must provide clear technological, social, or economic benefits such as cost efficiencies, qualitative efficiencies, initiations of new technologies, or environmental and sustainable benefits. Necessity of the agreement/activities: These benefits must not be achievable without the proposed agreement or activity. The applicant must show that prevention, restriction, or distortion of competition are essential to realizing the benefits. Benefits outweigh harm: The positive impacts must significantly outweigh any adverse effects caused by the prevention, restriction, or distortion of competition, and the benefits should be likely to materialize within one year. No elimination of competition: The agreement must not eliminate competition in any substantial aspect of goods or services. Application and Supporting Documents

On March 12, 2025, Cambodia’s Ministry of Economy and Finance issued Prakas No. 192 on Tax Rules and Procedures for Trust to determine the tax rules and procedures for trust operations. With the exception of trusts whose legal form is a company or enterprise, all trustors, trustees, and beneficiaries engaged in trust operations in Cambodia are subject to this new regulation. Taxpayer Registration A trustee company must register as a medium or large taxpayer. An independent individual trustee must register as a small, medium, or large taxpayer depending on the amount of turnover or the value of the fixed assets of the business, as stipulated in the Prakas on the Clarification of Taxpayers under the Self-Assessment Regime. Independent individual trustees must register as taxpayers within 15 working days from the commencement of economic activity or from the receipt of a license or authorization from the Trust Regulator. Accounting Records Accounting records should follow the rules stipulated in Article 6 of the Law on Taxation., which requires small taxpayers to use simplified accounting, while medium and large taxpayers must adhere to the Cambodian International Financial Reporting Standards (CIFRS).The trustee must maintain separate accounting records between its own operations and the trust. If the trustee manages more than one trust, the trustee must prepare separate records for each trust. For all the records, the trustee must clearly identify the ownership of all assets, liabilities, expenses, and other transactions. Taxation of Trustee’s Income Trust property or funds that are transferred to a trustee for management are not considered income or property of the trustee. However, any allowances or commissions that the trustee receives from managing the trust are taxed as income. The trustee must follow the general rules on expenses outlined under Cambodian tax law to record all income and expenses related

On May 6, 2025, Cambodia’s Ministry of Labor and Vocational Training (MLVT) issued Prakas No. 112/25 on Overtime Work, Work on Paid Holidays, and Suspension of Weekly Days Off, which outlines specific conditions, formalities, and procedures in relation to working overtime, work on paid holidays, and suspension of weekly days off. Overtime Work Employees may be requested to perform overtime work based on the operational needs of the employer, particularly in the following circumstances: When undertaking special assignments related to inventory and balance sheets, liquidation deadlines, and closing of accounting books. In cases of excessive workload arising from exceptional circumstances where alternative measures are not feasible for the employer. However, the overtime work must be conducted voluntarily and must not be enforced through coercion or disciplinary action. Although this new prakas on overtime work does not specify the maximum allowable hours of overtime work, the Labor Law states that overtime must not cause total working hours to exceed 10 hours per day, except in cases of disaster prevention or rectification. Work on Paid Public Holidays Employees are entitled to paid public holidays announced annually by the MLVT. However, when work cannot be suspended, employees may be requested to perform work on paid public holidays on a voluntary basis. Suspension of Weekly Days Off When urgent work is required to prevent imminent accidents or to repair damage to materials, facilities, or buildings, weekly days off may be suspended for up to two nonconsecutive days per month. This applies to both employees of the affected enterprise and those of external entities engaged in the repairs of the affected enterprise. Reduction of Weekly Days Off Due to Weather Certain categories of enterprises are permitted to reduce employees’ weekly days off by up to two nonconsecutive days per month as compensation for working

On May 6, 2025, Cambodia’s Ministry of Labour and Vocational Training (MLVT) issued Prakas No. 113/25, introducing new obligations for enterprise owners and directors regarding the use and maintenance of enterprise payroll books. Under this prakas, enterprise owners or directors are required to: Utilize and maintain the enterprise payroll book in accordance with the official template provided by the MLVT. Make the enterprise payroll book available to labor inspectors for annotations related to compliance with labor laws and regulations. Review and adjust (if necessary) internal practices based on any findings, recommendations, and restrictions issued by labor inspectors during inspections. The official enterprise payroll book template can be downloaded via the ministry’s Labor Automated Central Management System (LACMS). Additional requirements include: Retention of supporting documents related to the payroll book at the enterprise’s head office to facilitate inspections. Preservation of completed payroll books for a minimum of three years after their closure. Downloading a new payroll book from the LACMS once the current one is fully used. Labor inspectors are authorized to conduct inspections of the payroll book and related documentation at any time. Noncompliance with the provisions of Prakas No. 113/25 may result in significant monetary penalties, as stipulated in Cambodia’s Labour Law. This prakas also repeals Prakas No. 268, dated October 11, 2001, and any provisions in related regulations that conflict with Prakas No. 113/25. All enterprises are strongly advised to comply with the new requirements and begin using the updated enterprise payroll book template from the LACMS to avoid potential penalties.