1. INTRODUCTION

On 29 December 2000, the Royal Government of Cambodia issued Sub-Decree No. 103 to define the formality and the procedure for Civil Registration affairs in the Kingdom of Cambodia. The Sub-Decree has, until recently, been the primary legislation for civil status registration and the main source for registrars to use for civil registration in the Kingdom.
Responding to the population growth and the need for population management, the Law on Civil Registration, Vital Statistics and Identification (“LCRVSI”) was promulgated on 01 July 2023. This law sets out the rules and procedures relating to civil registration, residence registration, vital statistics, personal identification registration and population registry management, and this law applies to all persons living in territories of the Kingdom of Cambodia in addition to Cambodians living abroad. Whilst this law provides the framework, it is anticipated that many other regulations related to formality and procedure will be issued by the competent ministries and institution for effective implementation.

4. CONCLUSION

1) Law on Civil Registration, Vital Statistics and Identification was promulgated on 01 July 2023 and provides very comprehensive conditions and universal registration for civil registration and identification in Cambodia that comply with the United Nation Recommendations on Civil Registration and Vital Statistics. The law will be implemented one year after the promulgation, other than Art. 179, 180 and 180 which shall be implemented in accordance with the future Sub-Decrees.

2) There are several points of law and formality which are not yet clear, as the law refers to not-yet-issued Sub-Decrees and Prakas of the Ministry of Interior. Therefore, to effectively implement this law, the issuances of Sub-Decrees and Prakas or Inter-Ministerial Prakas clarifying the requirements, public service fee, form, formality and procedure are required.

3) The law does, however, undoubtedly improve the civil registration and identification process and should result in greater clarity, quality of service, lower payments, and ease of access.

1. INTRODUCTION

The Trust law (“TL”) of the Kingdom of Cambodia, promulgated on 02 January 2019, provided for four types of trusts: a commercial trust, a public trust, a social trust and an individual trust. Additionally, the financial trust was introduced by Sub-Decree No. 476 dated 26 August 2013.

An Environmental Trust (“ET”) was introduced by the Code of Environment and Natural Resources (“CENR”) or “the Code” promulgated on 29 June 2023. The purpose of an ET is to encourage environmental protection, sustainability, and conservation. According to Article 865 of the Code, the CENR will come into force one (01) year on from the promulgation of the Code. Therefore, the implementation of ETs shall commence from the beginning of July 2024.

4. CONCLUSION

An Environmental Trust is a new type of trust created by the Code of Environment and Natural Resource which was promulgated on 29 June 2023, and this code shall be implemented one (01) year from the promulgation.

An Environmental Trust is valid only if it is registered at the Ministry of Economy and, as executed by the Trust Regulator, in the same manner as other types of trusts under the Trust Law, 2019.

Environmental Trusts are very important for those who wish to manage and allocate funds for protecting the environment and natural resources through a trust mechanism once the Code of Environment and Natural Resource is implemented.

I– Introduction

In 2021 two regulations launched regarding VAT on E-Commerce as below:

III– Registration for Simplified VAT

The non-resident taxpayers provide digital goods / service / e-commerce activities into Cambodia shall register a Simplified VAT within 30 days if the annual turnover met from 250 million riels (US$ 62,000.00) or three (3) month consecutive period completed in the current calendar year meets from 60 million reals (US$ 15,000.00).

The Simplified VAT application is only used for the VAT obligation purpose. The non-resident taxpayer can apply the required form and documents by Khmer or English language for registering the simplified VAT through an e-registration via website http://www.tax.gov.kh or use the services of registered tax service agents. The required documents included:

• VAT application form;
• Oversea tax registration certificate of non-resident taxpayer;
• The valid ID card / passport of the owner or representative person;
• Two passport size photos of the owner or representative person;
• Bank account confirmation issued / printed by the bank of the non-resident taxpayer;
• 400,000.00 Riels (US$ 100.00) for the Simplified VAT registration;
• 100,000.00 Riels (US$ 50.00) for updating the information of the taxpayer, such as amendment of address, owner / representative personally, or name of the enterprise.

The Simplified VAT registered non-resident taxpayer should be received the documents as listed below from the tax administration after 7 to 10 working days since submitted all required forms and documents:

• Simplified VAT Certificate;
• Tax Registration Card;
• Notification of the tax obligation.

IV– Tax Obligation

V. Exempt from Tax Obligation

VI. Application of Withholding Tax on Simplified VAT Registered Nonresident Taxpayer Supplies

A simplified VAT registered nonresident taxpayer can only supply e-commerce goods or services to consumers in Cambodia. Withholding tax (WHT) is a type of tax that is withheld by a resident taxpayer from a payment made to a nonresident taxpayer. WHT is applied to certain types of income, such as income from services, royalties, and interest. The WHT rate for nonresident taxpayers in Cambodia is 14%. The simplified VAT registered nonresident taxpayer is not subject to WHT on their e-commerce supplies to consumers in Cambodia, as these supplies are subject to VAT. The simplified VAT registered on-resident taxpayer is only used for collecting VAT purposes.

VII. Issuing the Invoice

The simplified VAT registration taxpayer shall issue the supply / sale invoice containing to their consumers and resident taxpayer as below:

VIII. De-registerer from the Simplified VAT Registration

A simplified VAT registered nonresident taxpayer who wishes to cease e-commerce supplying into Cambodia must settle all outstanding VAT obligations to the tax administration before submitting a request letter to the General Department of Taxation. The request letter for de-registration of the simplified VAT registration must be submitted within 15 days after the cessation of e-commerce activities of goods or services into the Kingdom of Cambodia.

1. INTRODUCTION

On 16 May 2023 the Royal Kram promulgated the New Law on Taxation No. NS/RKM/0523/004. The New Law on Taxation is not a complete overhaul of the previous law, however it is designed with the purpose of improving, facilitating, filling gaps and improving the consistency of the previous law by compiling a set of laws related to tax, international tax and tax practices.

The old Law on Taxation, promulgated by Royal Kram No. NS/RK/0297/03, dated 24 February 1997, had 6 Chapters and 155 Articles only, whilst the New Law on Taxation includes 20 Chapters and 255 Articles.

We note some of the key features of the New Law on Taxation below:

2. NEW CHAPTERS

Whilst some of the new chapters were previously contained in the Law on Taxation, the chapters have been separated to provide clarity and consistency for the ease of understanding for taxpayers of their obligations. The new chapters include provisions for the following:

According to Sub-Decree 286 dated September 20, 2023 set out the Public Lighting Tax at a rate of five (5) percent for alcohol and tobacco products in Cambodia. The rule and procedure of collection shall be determined by Prakas by Ministry of Economic and Finance.

3. UPDATED DEFINITIONS

• Permanent Establishment (“PE”): A person has and regularly exercises the rights to sign on behalf of non-residents or performs the main duties in facilitating the process toward the signing of any contracts  may considered as a PE in Cambodia.
• Related Party: Any enterprises which directly or indirectly controls or is controlled by, is considered as having common control with the taxpayer.The term “Control” means ownership equal to or more than 20% of the value or voting right of the equity interests in the enterprise.
• Cambodia Sourced Income: Gains from movable or immovable properties sold, including intangible assets located in Cambodia; or
  Gains from the transfer of any interest in movable or immovable properties including intangible assets situated in Cambodia.
• Taxable Person: A non-resident person who supplies digital goods or services to the Cambodia shall be considered as taxable person (E-commerce).
• Taxable Supply: The supplies of digital goods or services in the Cambodia as stated in Art. 58 of New Law on Taxation (E-commerce).
• Public Lighting Tax: Based on the New Law on Taxation, the Public Lighting Tax shall be paid at the first (1st) time of supply only. However, the GDT will issue additional instructions to further clarify this.
• Stamp Duty: According to Art. 157(8), the term ‘property companies’ refers to all companies that occupy properties directly or indirectly with a direct or indirect property value of more than 50% of the total asset value of the company. However, Art. 158(1) states that the stamp duty relative to transfer the ownership or the right to occupy properties as constructions /land, placement of shares as properties, transfer shares, or similar interests of property companies is 4% of the total property value share/transfer.

4. DELIVERY OF INFORMATION TO THE TAXPAYER

A written letter/notification letter/electronic notification (includes faxes, emails, etc.) that the tax administration provides to the taxpayer shall impose an obligation on the taxpayer to the tax administration only when that letter/notification is made in written form and is delivered to the taxpayer.

The letter/notification shall be considered properly delivered if sent to the last address registered (includes email, address, faxes, etc.) with the tax administration.

5. SHARE TRANSFER, BUSINESS TRANSFER AND MERGER OF ENTERPRISES

Should there occur a business transfer or a transfer of shares, the new owner shall be responsible for all tax debts of the businesses/enterprises.

Should there occur a merger of two or more enterprises, the enterprise that continues or arises from the merger of two or more enterprises shall be responsible for all tax debts.

6. INCREASED PENALTIES

The New Law on Taxation increased the penalties and imprisonment term per table below:

Four (4) new crimes have been introduced in the New Law on Taxation:

7. GENERAL ANTI-AVOIDANCE RULE (“GAAR”)

The GAAR provides the GDT with the power to act against schemes that are designed for tax avoidance.

The additional powers of the tax administration, compared with the old LoT, provide the tax administration with the power to reject and/or redetermine the real substance of any transactions if they have found that the taxpayer has organized or carried out any transactions that show false or unrealistic intent in order to reduce or eliminate the tax payable which is contrary to the spirit of the tax provisions.

The Prakas on Unfair Contract Clauses (UCC), promulgated on March 01, 2022, serves as a cornerstone in the Cambodian legal framework, emphasizing the importance of “Standard Form Contracts.” This legislation aims to fortify consumer rights, ensuring transparency, fairness, and protection against undue profit exploitation in contractual relationships with business operators for goods and/or services within the Kingdom of Cambodia.¹.

Details of the Prakas on Unfair Contract Clauses (UCC) are outlined below:.

I- Scope

The Prakas is meticulously crafted to encompass all Standard Form Contracts designed for the provision of goods and/or services to consumers in Cambodia, in alignment with the definitions and provisions set forth in the Law on Consumer Protection.

IV- Identification of Unfair Contract Clauses

Clauses that absolve or limit the business operator’s liabilities concerning service/goods guarantees, as specified in the Civil Code, are deemed unfair.
Clauses that empower business operators to significantly alter the nature, quantity, cost, or quality of goods/services without prior consumer consent are flagged as unfair.
Clauses that permit business operators to modify essential contract clauses without prior notification or consumer consent are considered unjust. Clauses granting unilateral and arbitrary interpretation or termination rights to the business operator are also categorized as unfair (Art.9).

V- Unfair Practices and Repercussions

Employing unfair contract clauses prohibited by this Prakas is deemed an unfair practice under the Law on Consumer Protection.
Non-compliant business operators will face penalties, ensuring accountability and adherence to the provisions of the Law on Consumer Protection.
These penalties do not absolve the violator from broader criminal and civil liabilities as per other pertinent legal frameworks.

VI- Mechanism for Dispute Resolution

In case of disputes, consumers or any aggrieved party can lodge a complaint independently or via a sectoral consumer association. Complaints can be addressed to the National Commission for Consumer Protection or other competent authorities. Disputes will be adjudicated as per the resolution mechanism delineated in the UCC Prakas (Art 14, PUCC).

1. INTRODUCTION

Generally, franchising is known as a business model for companies who wish to expand their market share rapidly, and less expensively, through a licensing relationship. In this regard, the owners (“the Franchisor”) of a company wishing to expand their business grant a license to a third party (“the Franchisee”), to conduct business under its trademark and business operating methods, within a specific territory, according to the agreed terms of a contract (“the Franchise Agreement”). In other words, franchising is also known as an investment model, where the franchisee uses the franchisor’s successful business operating methods and trademark, to operate a similar, or identical, business, by paying a fee, and/or royalties to the franchisor. In international practice, there are two different types of franchise: a business format franchise, or a traditional or product distribution franchise. The former is more common, as the franchisor provides to the franchisee, not just its trade name, goods and services, but an entire system for operating the business. The latter type is less common because it basically only involves the products manufactured, or supplied, by the franchisor to the franchisee ¹.

3. REQUIREMENTS FOR RECORDAL/ REGISTRATION

As provided in Article 52 of the Trademark Law, any license contract shall be recorded with the Ministry of Commerce, though its contents will remain confidential. This contract shall have no effect against third parties until such recording is executed.

Article 27-3 of Sub-Decree on the Implementation of the Law Concerning Marks, Trade Names and Acts of Unfair Competition of the Kingdom of Cambodia (the “Sub-Decree on Trademarks”) stipulates that a licensing contract submitted for recordal under Article 52 of the Trademark Law must be accompanied by a copy of trademark registration certificate, a notarized Power of Attorney and an original copy of the Licensing Contract or its certified copy. The parties shall file the request for recordal of the franchise agreement/trademark license agreement either before or within six (06) months from the date of signature of the franchise agreement ².

Article 6 of the Sub-Decree on Recordal of License or Franchise Agreement also stipulates that the contract is an object of recordal request, and therefore must clarify the important meanings of the agreement, as below:

1. Identity of provider and recipient as:
   • Name, Nationality and permanent address if provider and recipient is individual; or
   • Name, Nationality and Headquarters’ registered address if the provider and recipient is a Legal Entity
2. Detail on the Trademark such as Trademark, registered number or Trademark registration number, Category of goods or services and types of goods or services which are the objects for recordal request.
3. Typically the type of License or Franchise which is given by the contract: Exclusive, Non-Exclusive, Single or Third-Party contract.
4. Duration of permission is specific set in the contract or is set by the conditions and regulation which are written on other related contracts.
5. Duration of permission is specific set in the contract or is set by the conditions and regulation which are written on other related contracts.
6. Signature of both parties and verification by notary or competent authority.

Based on practice, the registrar requires additional documentation such as the notarized extract of the summary franchise agreement and the translation of the extract of the summary franchise agreement into Khmer language and certified by the trademark agent. Kindly note that there are two professional translators that are recognized by the Department of Intellectual Property of the Ministry of Commerce, being the aforesaid trademark agent and Pyramid Translation Services. Therefore, the parties can choose which one they prefer to translate the agreement.

In summary, current required documents for recording trademark license agreement/franchise agreement in Cambodia are as follows ³:

• Notarized Copy of the License/Franchise Agreement;
• Copy of Trademark Registration Certificate(s);
• Notarized Power of Attorney to BNG from both franchisee and franchisor (drafted by BNG);
• Request Form for Recordal of License Agreement (provided by BNG);
• Original Signed and Notarized Extract Summary of Master Franchise Agreement (Summarized by trademark agent/professional translator which is recognized by the Ministry of Commerce); ⁴
• Certified copy of translation of Extract Summary of Master Franchise Agreement (Translated into Khmer language and certify by the trademark agent); and
• Extract of Company Registration from Ministry of Commerce and Patent Certificate (if the franchisee is Cambodian).

Please also be advised that the licensed trademark shall be registered in Cambodia prior to the recordation of the license agreement.

4. CONCLUSION

Despite there being no specific provision governing franchising in Cambodia, this kind of business model is considered very popular, and its use is expanding rapidly. While most Cambodians enjoy the benefits of branded goods and services, setting up a franchise is strongly recommended. To do so, the franchise agreement must comply with the rules of the license agreement, stipulated in the Trademark Law. Any franchise agreement concluded and exercised within the Kingdom of Cambodia must be in compliance with relevant laws and regulations, namely the Civil Code, the Trademark Law, the Law on Taxation and the Labour Law. It is recommended that both the franchisor and the franchisee consult with a qualified lawyer, before concluding any franchise agreement.

1 https://www.franchise.org/faqs/basics/what-is-a-franchise

2 Notification 07 dated 06 August 2015 on Recognition of Exclusive Rights on the Use of Trademark and Prokas No.0117 dated 25 June 2021 on Procedure to Certification and Recordal of

3 Prakas No.036 dated 13 January 2020 on Recordal of License and Franchise Contracts;

4 Notification No.0748 dated 12 March 2015 on Recordal of Trademark License Agreement or Franchise Agreement;

1. INTRODUCTION

The National Social Security Fund (“NSSF”) has long been established to provide security for employees in Cambodia. Whilst initially focusing on health insurance, in recent years it has expanded into also providing pension provisions. Sub-Decree No. 32 on the Social Security Scheme on Pension for Persons Defined by the Provisions of the Labour Law, promulgated on 04 March 2019 initiated this shift, and its provisions have been clarified in further Sub-Decrees and Prakas. This newsletter will explore the requirements of employers, the benefits of employees and the implementation of the law.

2. REGISTRATION OF THE NSSF

All employers with one (01) or more worker is required to register with the NSSF. The process for registration with the NSSF was set out in Prakas No 168/22 on the Formalities and Procedures for Registration of Company, Employee and Contribution Payment for Persons Defined Under Provisions of the Labour Law, enacted on 05 July 2022.

An employer is required to register within 30 days of commencing activities. Any new employees must also be registered by the employer within three (03) days of beginning employment.

Non-registration with and failing to pay the contributions to the NSSF can lead to a fine of 30 times the base daily wage rate, which was increased to US$ 20.00 with the implementation of Inter-Ministerial Prakas No. 326 on Base Daily Wage dated 25 November 2022. Therefore, lack of registration and failing to pay the contributions can result in a fine of up to approximately US$ 600.00. The fines shall be calculated according to the number of workers whose contributions are deducted by employers and in violation of the provisions of this law.

3. CONTRIBUTIONS OF THE PENSION SCHEME

In general, contributions are made by the employer on a monthly basis. The contributions required for the first five (05) years of employment are set at 4% of an employee’s wage. The contribution shall be borne as follows:

• 2% from the employer; and
• 2% from the employee.

4. PENSION ENTITLEMENTS OF EMPLOYEES

Employees are entitled to either an old age pension, an old age allowance, or an invalidity pension. In addition, a survivor’s pension is available to the family members of those who were entitled to one of the pensions listed.

5. FOREIGN EMPLOYEES

The pension schemes shall apply to persons defined by the provisions of the Labour Law including persons who have 2 (two) or more jobs. Based on Article 3 of Sub-Decree No. 32, employee refers to all kinds of employees and all nationalities of the formal sector including persons defined by the provisions of the Labour Law. Therefore, the foreign employees are obliged to pay the contribution and are entitled to pension benefits.

6. CONCLUSION

The pension schemes shall apply to persons defined by the provisions of the Labour Law including persons who have 2 (two) or more jobs. Based on Article 3 of Sub-Decree No. 32, employee refers to all kinds of employees and all nationalities of the formal sector including persons defined by the provisions of the Labour Law. Therefore, the foreign employees are obliged to pay the contribution and are entitled to pension benefits.

1. The director or owner of an enterprise defined by Labour Law should register their enterprise and employees in accordance with the existing laws and regulations and pay the contribution into the pension fund in compliance with Sub-Decree No. 32 to avoid any possible fines and for the benefits of their employees.
2. Whilst all enterprises are required to pay contributions to a pension fund, providing these benefits to employees through NSSF rather than a private insurance company can reduce expenditure.

1. INTRODUCTION

As of 2021 there were stated to be 54 Special Economic Zones (“SEZs”) in Cambodia, spanning the entirety of the country, with zones in Sihanoukville in the south, the capital Phnom Penh and in border towns such as Bavet. SEZs were created in two pieces of legislation promulgated on the same day; Sub-Decree 147 on the Organisation and Function of the CDC and Sub Decree 148 on the Establishment and Management of Special Economic Zones, which both came into force on 29 December 2005. The function of these special economic zones is to stimulate growth in the Cambodian economy by incentivising investment, primarily in the manufacturing sector, by providing tax incentives, improved infrastructure and a simplified method of operation in Cambodia. This newsletter will set out the procedures of setting up a company in an SEZ as well as the investment incentives available.

2. PROCEDURE

To set up in a Special Economic Zone, a company must become a Qualified Investment Project (“QIP”), the status of which is granted by the Council for the Development of Cambodia (“CDC”). Most SEZs have a one stop shop within its own borders, enabling an investor to complete the entire process with the SEZ administration rather than dealing directly with the CDC. In general, the application procedure follows the following steps:

• Submission of an Investment Proposal to the CDC
• Issuance of the Conditional Registration Certificate (“CRC”)
• Company registration with the Ministry of Commerce (“MOC”)
• Obtaining all necessary licenses from the relevant ministries as listed in the CRC, on behalf of the Applicant
• Registration with the General Department of Taxation (“GDT”)
• Construction plan approval from the local authorities and the Ministry of Land Management, Urban Planning & Construction
• Environmental Impact Assessment as performed by the Ministry of Environment
• Environmental Impact Assessment as performed by the Ministry of Environment
• Issuance of the Final Registration Certificate

3. BENEFITS UNDER THE NEW LAW ON INVESTMENT

The new Law on Investment, promulgated on 15 October 2021, aims to establish an open, transparent, predictable and favourable legal framework to attract and promote quality, effective and efficient investment by Cambodian nationals or foreigners. This is to enable socio-economic development in the Kingdom of Cambodia, by increasing Cambodia’s competitiveness, increasing the productivity of local industries, establishing an investment incentives regime and providing protection to investors’ rights. The new Law states that a project set up in a SEZ is considered as a Qualified Investment Project (“QIP”) and therefore is entitled to the investment incentives outlined in the legislation. The incentives available to projects in an SEZ are referred to as basic and additional incentives.

4. ADVANTAGES OF OPERATING IN AN SEZ IN CAMBODIA

There are SEZs in operation in much of the developing world, and thus attracting foreign investment of this kind is highly competitive. In addition to the simple one stop shop procedure, reasonable time frame for establishment and the investment incentives outlined above, there are other advantages for choosing to operate in a Cambodian SEZ:

5. CONCLUSION

The rapid growth of SEZs in Cambodia since their introduction in 2006 demonstrates their enduring ability to attract investment. With the relatively simple and speedy set up process combined with the additional benefits conferred upon QIPs by the recently promulgated Law on Investment, operating within an SEZ can become an even more attractive proposition. With its improving infrastructure and its central geographical location, Cambodia is positioning itself as a major manufacturing hub for the next decade and beyond.

1. INTRODUCTION

Whilst gambling for Cambodian citizens is not permitted under Cambodian law, the gambling industry has seen incredible growth in Cambodia over the past decade, ostensibly to service foreign clients. To this end, border towns such as Bavet and Poipet have a large number of casinos to allow citizens of neighbouring countries, where gambling is illegal, to partake. In addition, the southern town of Sihanoukville has seen incredible growth in the number of casinos in the past decade, culminating in a nationwide total of 193 casinos in 2020. To bring clarity and increased oversight to the sector, the Royal Government introduced the Law on Management of Commercial Gaming in 2020, and further clarified the regulations in subsequent Sub-Decrees. This newsletter will focus primarily on the licensing and requirements for casino-based gambling.

2. GAMBLING ZONES

The Law on Commercial Gambling Management separated the commercial gambling zones into two types: (1) prohibited zones and (2) permitted zones. In prohibited zones, all or certain types of commercial gambling are prohibited for the purpose of preserving culture, religion, or other reasons. The permitted zones are those geographical areas located outside of the prohibited zones. . Permitted zones also cover casino games and betting which are only permitted within the premises of a casino.

3. COMMERCIAL GAMBLING REGULATOR

The Commercial Gambling Committee of Cambodia (CGCC) is the competent authority responsible for issuing all relevant licenses relating to centers operating commercial gambling and commercial gambling activities in Cambodia. Commercial gambling refers to casino gambling, betting gambling, luck-based gambling and/or other commercial gambling operated for the purpose of making profits or for business purposes. Pursuant to the Gambling Law, subject to the types of commercial gambling and related activities, the CCG, may issue the following licenses:

• Casino gambling
• Betting gambling
• Luck-based gambling
• Other commercial gambling
• Special employees
• Promotors (junkets) and
• Manufacturers, installers, importers, sellers and/or distributors of equipment and/or gambling software.

4. TYPES OF CASINO LICENCES

5. Meetings

The requirements for an application for a casino gambling licence are as follows:

• Being a company legally established and registered (with company and tax registration) under Cambodian Laws and having a governing structure which clearly determines the duties and responsibilities, ensuring accountability, transparency, effectiveness, and good corporate governance.
• Having enough financial and human resources with the required knowledge, ability and experience based on their position in the company.
• Having enough infrastructure and IT system to provide service as casino operator and Backup System to ensure safe and effective operation.
• Having location equipped with enough instruments for casino operation.
• Having system and policy on risk management and internal control.
• Having business control mechanism on casino operation.

6. MINIMUM CAPITAL REQUIREMENTS

The minimum capital requirement for casino operators within integrated resorts shall be at least KHR 800,000,000,000 (approx. US$ 200 million), whilst that for casino operations outside integrated resorts shall be at least KHR 400,000,000,000 (approx. US $100 million).

Prior to the enactment of the Law, there were no integrated resorts as all existing casino operations were considered as stand-alone operations (i.e., outside integrated resorts). For these existing casino operators duly licensed to operate prior to the enactment of the Law, the minimum capital requirement of at least KHR 400,000,000,000 (approx. US$100 million) must be satisfied over a period of time. This minimum capital requirement shall be implemented in five phases as follows:

7. LICENSING PROCEDURE & TIMEFRAME

8. APPLICATION & STUDY FEE