The General Department of Taxation (GDT) has announced the market interest rates for related-party loans for the 2025 tax year, providing a benchmark for transfer pricing compliance.

NOTIFICATION NO. 5097 GDT ON MARKET INTEREST RATE FOR LOAN FROM RELATED PARTIES IN 2025 DATED 11 FEBRUARY 2026

Market Interest Rates for Related Party Loans 2025

This notification informs taxpayers about the market interest rates applicable to loans obtained from related parties for the fiscal year 2025. The rates are based on the annual average interest rates offered by 12 major local commercial banks. Specifically, the yearly interest rate is set at 9.36% for Khmer Riel loans and 8.45% for US Dollar loans, providing a benchmark for fair loan pricing among related parties.

The Notification was issued to inform taxpayers of the applicable market interest rates for related-party loans in 2025. These rates are intended to serve as a benchmark for determining arm’s-length pricing in financing transactions between related entities, thereby supporting compliance with transfer pricing requirements and ensuring that such transactions are conducted on fair and reasonable terms.

The market interest rates were determined based on the annual average lending rates reported by 12 major local commercial banks. For the 2025 tax year, the market interest rate applicable to loans denominated in Khmer Riel is set at 9.36% per annum, while the market interest rate for loans denominated in United States Dollars is 8.45% per annum. Taxpayers engaging in related-party financing arrangements may use these rates as a guideline when assessing the appropriateness of interest charges for transfer pricing purposes.