French pension taxed in Cambodia
French pension and Cambodian tax — progressive ToS brackets, theory vs GDT practice, French tax obligations, double taxation with no FR-KH treaty.
- Difficulty
- Complex
- Reading
- 10 min
In 3 bullets
- Yes in theory: as a Cambodian tax resident (>182 days/year), your French pension is subject to the ToS — but on a progressive scale, not a flat rate.
- On 1,500 €/month, the theoretical ToS is ≈ 122 USD/month (average rate ~7.4%), not 10% of the whole amount.
- France and Cambodia each tax independently: no bilateral tax treaty is in force as of June 2026 — no automatic mechanism to eliminate double taxation.
Who is concerned
This guide is for French retirees planning to settle long-term in Cambodia (renewable ER or EB visa) while receiving a French pension as their sole income.
You are in this situation if:
- Your pension is paid by a French fund (CNAV, AGIRC-ARRCO, public sector, special schemes).
- You plan to spend more than 182 days per year in Cambodia.
- You carry out no paid activity on the ground.
Calculating Cambodian tax on a pension
The ToS is progressive, not a flat rate
Cambodia’s Tax on Salary ( ToS ) works like French income tax: by brackets. Only the portion of income above each threshold is taxed at the higher rate. Exchange rate used: 1 € = 1.10 USD, 1 USD = 4,100 KHR (NBC rate).
| Monthly bracket (KHR) | ≈ USD | Rate |
|---|---|---|
| 0 – 1,500,000 | 0 – 366 | 0% |
| 1,500,001 – 2,000,000 | 366 – 488 | 5% |
| 2,000,001 – 8,500,000 | 488 – 2,073 | 10% |
| 8,500,001 – 12,500,000 | 2,073 – 3,049 | 15% |
| > 12,500,000 | > 3,049 | 20% |
Source: Sub-Decree 196 / 2022, GDT.
Detailed example: pension of 1,500 €/month
Conversion: 1,500 € × 1.10 = 1,650 USD × 4,100 = 6,765,000 KHR
Income passes through each bracket from the bottom up. The “Taxable amount” column shows the width of the portion of income falling in that bracket — the difference between the upper and lower boundary, not the upper boundary itself.
- 0% bracket: from 0 to 1,500,000 KHR → width = 1,500,000 − 0 = 1,500,000 KHR
- 5% bracket: from 1,500,000 to 2,000,000 KHR → width = 2,000,000 − 1,500,000 = 500,000 KHR (not 2,000,000)
- 10% bracket: from 2,000,000 up to our income of 6,765,000 KHR → width = 6,765,000 − 2,000,000 = 4,765,000 KHR
| Bracket | Taxable amount (width) | Rate | Tax |
|---|---|---|---|
| 0 – 1,500,000 KHR | 1,500,000 | 0% | 0 |
| 1,500,000 – 2,000,000 KHR | 500,000 | 5% | 25,000 KHR |
| 2,000,000 – 6,765,000 KHR | 4,765,000 | 10% | 476,500 KHR |
| Monthly total | 6,765,000 ✓ | 501,500 KHR ≈ 122 USD ≈ 111 € |
The sum of the widths (1,500,000 + 500,000 + 4,765,000) must always equal the total income (6,765,000 KHR) — this is the natural verification of the calculation.
Effective average rate: ≈ 7.4% — not 10% of the whole amount.
Quick table by pension level
| Monthly pension | ≈ KHR | Monthly ToS ≈ | Average rate |
|---|---|---|---|
| 800 € | 3,608,000 | ~45 USD (~41 €) | ~5.1% |
| 1,000 € | 4,510,000 | ~67 USD (~61 €) | ~6.1% |
| 1,500 € | 6,765,000 | ~122 USD (~111 €) | ~7.4% |
| 2,000 € | 9,020,000 | ~184 USD (~167 €) | ~8.3% |
| 2,500 € | 11,275,000 | ~266 USD (~242 €) | ~9.7% |
Assumption: 1 € = 1.10 USD, 1 USD = 4,100 KHR. Recalculate if the NBC rate changes. These amounts are theoretical — see the next section on GDT practice.
Theory vs GDT practice
What the law says
A Cambodian tax resident (>182 days/year) is taxable on their worldwide income, including a foreign pension even if deposited into a French account.
What the GDT does in practice
The GDT focuses its checks on income of Cambodian origin (salaries from KH employers, activities carried out on KH soil). In practice, it does not pursue foreign pensions received into foreign accounts, except in three trigger cases:
- The pension is wired to a Cambodian account (ABA, ACLEDA, WING) — visible in the local banking system.
- An administrative procedure requires proof of income: ER visa renewal, condo purchase, account opening > 50,000 USD.
- The retiree has voluntarily registered with the GDT (obtaining an individual TIN).
The French side — what you need to do
Non-resident withholding tax (PAS NR)
When you become a French non-resident for tax purposes, your pension fund is required to apply a non-resident withholding tax (PAS NR — Prélèvement à la Source Non-Résidents) on each payment. This withholding replaces income tax for non-residents.
The rate applies to the net amount (after a 10% allowance) and varies by bracket:
- 0% for the lowest amounts.
- 12% for the intermediate bracket.
- 20% for the highest bracket.
Key point: if you were not taxable in France as a resident, your PAS NR will probably be 0% or very low. It is not an automatic extra penalty.
To check your personalised rate: your personal account at impots.gouv.fr or by contacting the SIPNR (Service des Impôts des Particuliers Non-Résidents).
Average rate option: if your French average rate (calculated on your worldwide income) is lower than the rate withheld, you can ask the DGFiP to apply it — this can reduce the withholding.
Annual filing obligations in France
Even as a non-resident, you must file each year:
| Form | Why |
|---|---|
| 2042-NR | Declare the pension of French origin. |
| 3916 | Report any bank account held abroad (ABA, ACLEDA…). Fine: €1,500 per undeclared account. |
| 2047 | If you pay tax in Cambodia and wish to claim a unilateral tax credit (to discuss with a tax adviser). |
No treaty — no automatic tax credit
No France-Cambodia tax treaty is in force as of June 2026 (negotiations since late 2023, not yet signed). If you pay ToS in Cambodia and withholding tax in France, there is no bilateral mechanism to avoid double taxation. Both countries tax independently.
Documents and procedures
To become a French non-resident for tax purposes
- Contact the SIPNR by post or via your impots.gouv.fr account.
- Attach: KH long-stay visa (ER or EB) + lease or accommodation certificate in Cambodia.
- Inform your pension fund (CNAV, AGIRC-ARRCO…) of your new foreign address so it can apply the PAS NR.
If you voluntarily declare to the GDT
- Obtain a TIN (individual tax identification number) from the GDT .
- Monthly ToS declaration on the tax.gov.kh/en/e-service portal.
- Payment before the 20th of the following month, in KHR.
Common pitfalls
FAQ
Will my pension fund automatically deduct the PAS NR?
Yes, as soon as you notify it of your address abroad (or the French tax authority notifies it of your change of status). Check your rate via your personal account at impots.gouv.fr or by contacting your fund directly.
Can I remain a French tax resident while living in Cambodia?
Formally, yes, if you retain a home or economic interests in France. But if you spend >182 days/year in Cambodia, the GDT also considers you a resident. Without a treaty, you would be taxable in both countries on the same income. This is the situation to avoid.
What if I stay fewer than 183 days a year in Cambodia?
You are not a KH tax resident. Your pension is not subject to Cambodian ToS. In return, you cannot benefit from the ER (retirement) visa, which requires an extended stay — you will be on short visas with regular exits.
Is the France-Cambodia treaty close to being signed?
Negotiations began in late 2023 and the 3rd round took place in January 2025. No signature date is public as of June 2026. Follow updates via the Assemblée des Français de l’Étranger (AFE) or written questions to the French Senate.
Do I need to register with the GDT to renew my ER visa?
No — GDT registration and immigration are two independent administrations. The ER visa is renewed by the General Directorate of Immigration, not by the GDT. However, if a proof of income check is requested (which is rare for an ER visa), a pension certificate in KHR or USD is usually sufficient.
Sources (4)
Every fact in this guide comes from official documents or government sites. An access date is recorded for each source.