Slides from the TAFTAC Tax Forum 2026:

Why VAT refund readiness matters 

The VAT refund process is one of the most important practical tax matters for exporters, qualified investment projects, and other enterprises with sustained input VAT credits. At TAFTAC Tax Forum 2026, the VAT refund session provided a valuable platform for public-private dialogue among the tax administration, industry representatives, tax professionals and the private sector. 

The key message is that a VAT refund should not be viewed only as a final application process. It is the result of disciplined monthly compliance, reliable supporting documents and consistent data across the taxpayer’s accounting records, e-filing submissions and supplier information. 

Core requirements under Instruction No. 018

Cambodia’s evolving VAT framework places strong emphasis on transparency, consistency and timely disclosure. Under MEF/GDT Instruction No. 018 on the procedure for tax credit applications and VAT refund requests, medium and large taxpayers should ensure that they: 

• request tax credits through GDT e-filing; 

• claim input VAT only for taxable supplies or imports used in making taxable supplies; 

• maintain sufficient supporting documents, including original tax invoices and import documentation; and 

• submit VAT refund requests through e-filing when the taxpayer has excess input VAT credits for three consecutive months, particularly for exporters and QIPs. 

Common practical challenges

The practical challenges raised by taxpayers are familiar and often arise from data or documentation gaps, including: 

• invoice mismatches between the buyer and the supplier; 

• input VAT claimed in the wrong month; 

• VAT credits carried forward for an extended period without timely action; 

• suppliers with unresolved tax issues; 

• outstanding taxpayer liabilities; and 

• incomplete evidence of payment. 

These issues do not always mean that the entire refund claim is invalid. However, unresolved exceptions can delay the review, result in partial disallowance, or suspend the request until the taxpayer provides additional records or resolves the relevant compliance matter. 

What an audit-ready VAT refund file should include 

A strong VAT refund file should be treated like an audit-ready file. It should include: 

• the refund application and e-filing schedules; 

• monthly VAT returns and accounting ledgers; 

• original tax invoices and import declarations, where relevant; 

• payment evidence and supplier reconciliations; 

• management explanations for unusual transactions; and 

• evidence that enterprise information and bank account information registered with GDT are up to date. 

Recommended approach for businesses 

The most important professional recommendation is to move from reactive refund filing to proactive refund governance. Businesses should: 

• reconcile VAT data monthly; 

• resolve invoice mismatches quickly; 

• maintain a supplier validation process; 

• keep a clear record of disputed invoices; 

• monitor outstanding tax liabilities before filing; and 

• perform periodic VAT health checks before submitting refund applications.