No VAT on EV Charging Until End-2028: What Prakas No. 715 Means for Charging Investors
At a glance
On 13 October 2026, the Ministry of Economy and Finance (MEF) signed Prakas No. 715 MEF.Prk.GDT on the suspension of value added tax (VAT) on electric vehicle (EV) charging services until the end of 2028. Operators must not charge VAT to users and cannot credit input VAT on station-related imports and local purchases. This note examines the statutory trade-off, financial impact on capex and opex, operator scenarios, and key compliance considerations.
Output VAT on EV charging services is temporarily suspended until 31 December 2028 under MEF Prakas No. 715.
Input VAT paid on equipment imports and local station purchases cannot be credited, becoming a direct project cost.
The Prakas sets no retail charging price, leaving operators to balance pass-through savings against absorbed VAT costs.
Operators must prepare customer contracts, billing software, and investment timing for the return of normal VAT in 2029.
At a glance
On 13 October 2026, the Ministry of Economy and Finance (MEF) signed Prakas No. 715 MEF.Prk.GDT on the suspension of value added tax (VAT) on electric vehicle (EV) charging services. The Prakas took effect on the date of signature and was posted on the General Department of Taxation (GDT) register on 20 October 2026. Until the end of 2028, operators of EV charging stations must not charge VAT on charging services. In exchange, they cannot credit the input VAT they pay on imports and local purchases for the station.
- Authority: Ministry of Economy and Finance; implemented by the GDT.
- Scope: Self-assessment taxpayers carrying on the business of operating EV charging stations in Cambodia (Art. 2).
- Relief: VAT on EV charging services suspended until the end of 2028 (Art. 3).
- Trade-off: No output VAT may be charged to users, and input VAT on station-related imports and local purchases is not creditable (Art. 4).
- Effective: From the date of signature, 13 October 2026 (Art. 6).
What does the Prakas say?
The Prakas is short: six articles over two pages. We reviewed the official Khmer text article by article:
This is a suspension, not a free pass. Customers stop paying VAT, but the operator bears the input VAT on its own costs. For capital-heavy charging businesses, this trade-off decides whether the measure helps or hurts margins.
- Art. 1 – Purpose: It suspends VAT on EV charging services to lower costs for users and to encourage investment in EV charging stations.
- Art. 2 – Scope: It applies to self-assessment taxpayers carrying on the business of establishing EV charging stations in the Kingdom of Cambodia.
- Art. 3 – Relief: These enterprises receive a temporary suspension of VAT on EV charging services until the end of 2028.
- Art. 4 – Conditions during the relief period: (a) The enterprise must not charge VAT to users on EV charging services. (b) VAT the enterprise has paid on imports or local purchases used for the activities and business operations of the EV charging station is not allowed as an input VAT credit.
- Art. 5 – Repeal: Any provisions contrary to the Prakas are repealed.
- Art. 6 – Implementation: MEF and GDT units implement the Prakas from the date of signature.
The preamble cites the Law on Taxation (promulgated 16 May 2023) and Sub-Decree No. 49 ANKR.BK of 11 March 2024 on VAT.
What the Prakas does not do matters too. It does not exempt the purchase or import of EVs or charging equipment from VAT. It does not set or cap charging prices. It does not change profit tax, customs duty or licensing requirements.
Suspension, exemption and normal VAT compared
The Prakas uses the term "suspension" (ព្យួរទុក), not "exemption". The economic result is close to an exemption without input credit, but the legal character is different.
The 10% standard rate is confirmed in GDT published guidance and the Council for the Development of Cambodia's tax summary.
| Feature | Normal VAT (10% standard rate) | VAT suspension under Prakas No. 715 | VAT exemption (statutory) |
|---|---|---|---|
| Output VAT charged to customers | Yes, 10% | No, until end of 2028 | No |
| Input VAT on station costs | Creditable against output VAT | Not creditable (Art. 4(b)) | Generally not creditable |
| Who bears VAT on capex and opex | Effectively passed to end users through output VAT | The operator, as a cost | The supplier, as a cost |
| Duration | Ongoing | Temporary, ends at end of 2028 | Ongoing until the law changes |
| Legal basis | Law on Taxation; Sub-Decree No. 49 | MEF Prakas (ministerial instrument) | Law on Taxation |
| Main benefit to | Neutral | Consumers (lower price); operators only where prices or demand respond | Consumers |
Illustrative example: the input-VAT cost effect
This is an illustrative example using hypothetical figures. It is not based on any real operator and simplifies the VAT rules (for example, it ignores timing, refunds, carry-forward of credits and profit tax).
A charging operator invests US$200,000 (excluding VAT) in chargers, transformers and civil works in year 1. It buys US$100,000 (excluding VAT) of VAT-bearing goods and services a year for operations, such as maintenance, software and site services. Its charging revenue is US$300,000 a year before any VAT.
- Year 1 under normal VAT (10%): Output VAT charged to customers: US$30,000 (customers pay US$330,000). Input VAT paid: US$20,000 on capex + US$10,000 on opex = US$30,000. Net VAT payable: US$0. The operator's VAT cost is nil; customers fund the VAT.
- Year 1 under the Prakas No. 715 suspension: Output VAT: nil (customers pay US$300,000). Input VAT paid: US$30,000, not creditable. The US$30,000 becomes a real cost: US$20,000 is added to the cost of the station assets (recovered through depreciation), and US$10,000 is an operating expense.
- Years 2–3 (opex only): Under normal VAT, the US$10,000 a year of input VAT would be credited. Under the suspension, it is an extra US$10,000 a year of cost.
- Result over 2026–2028 (simplified): Customers save about US$90,000 in VAT (US$30,000 a year). The operator absorbs about US$50,000 of non-creditable input VAT (US$20,000 capex + 3 × US$10,000 opex). The measure helps the operator only if the lower price to customers brings more usage, or lets it raise its pre-VAT price, by enough to cover that cost.
Three conclusions follow:
Commercial conclusions on capex and pricing
- Capex timing matters: Equipment bought during the suspension carries non-creditable VAT. Its cost stays in the asset base after 2028 even when charging becomes VAT-able again.
- Duty cuts soften the blow: Since 1 April 2026, import duty on EV charging equipment has been 0% (see "Related context"), so the non-creditable VAT is levied on a lower customs value.
- Pricing is a commercial choice: The Prakas sets no price. Whether operators pass the full 10% saving to customers, or keep part of it to offset their input VAT cost, is up to them, subject to MME pricing rules.
Scenarios for operators
Businesses encounter different commercial realities depending on their operating structure:
- 1. A standalone charging operator: For a business whose only activity is EV charging, the effect is simple: no VAT on sales and no input credit. The operator should remodel its pricing and payback period on a VAT-inclusive cost basis for 2026–2028; consider whether large equipment orders should be timed, phased or leased, keeping in mind that leasing fees will likely also carry non-creditable VAT; and check whether any non-charging revenue (advertising screens, parking fees, retail, battery swapping) stays VAT-able, and whether input VAT on shared costs can be apportioned.
- 2. A mall, hotel or office building adding chargers: Here charging is a small part of a mainly VAT-able business. The key issues are: whether property owners offering charging as an add-on qualify under Art. 2; apportioning shared costs (electricity supply upgrades, car-park works, building management) fairly between VAT-able activity and suspended charging; handling bundled pricing where charging is combined with parking or hotel rooms; and dealing with third-party operators running chargers under a site licence where the property owner charges VAT-able rent.
- 3. A solar-plus-charging operator: Operators combining rooftop or ground-mounted solar, storage and chargers face a mixed picture: input VAT on solar panels, inverters and batteries used for the charging station is blocked by Art. 4(b); where the same solar system also supplies a building or sells electricity, its input VAT must be split; import duty on solar systems and lithium batteries was cut to 0% from 1 April 2026 under Sub-Decree No. 52, lowering the import VAT base; and electricity supply, generation licensing and grid connection remain subject to energy-sector rules separate from the Prakas.
Planning for after 2028
The suspension ends at "the end of 2028" (ដំណាច់ឆ្នាំ២០២៨), which we read as 31 December 2028. Unless the MEF extends it, charging services will return to normal VAT from 1 January 2029. Investors should plan now:
- Price communication: Prices to customers will rise by up to 10% if operators pass VAT on. Customer terms, app pricing and subscription plans should allow VAT to be added from 2029.
- Long-term contracts: Fleet, ride-hailing or corporate charging agreements running past 2028 should say clearly whether prices exclude VAT and that VAT will be added when it applies.
- Capex scheduling: Inputs bought from 2029 should be creditable again, assuming normal VAT rules return. Large replacements or expansions planned around the cut-off may benefit from timing.
- Extension risk: A suspension can be extended, changed or ended early by a later prakas. Financial models should test both an extension and a return to VAT in 2029.
Practical compliance points
- Invoicing without VAT: Charging invoices and receipts issued during the period should show no VAT. Art. 4(a) says VAT must not be charged to users. An operator that wrongly shows VAT on an invoice risks having to pay it over.
- Non-creditable input VAT: Do not claim input VAT on charging-station purchases in the monthly VAT return. Record it as part of asset cost (capex) or as an expense (opex), and keep a clear audit trail tying each purchase to the station.
- Mixed businesses: Keep separate cost centres or ledgers for charging and other activities, and document the apportionment of shared costs.
- Registration status: The relief applies to self-assessment taxpayers (Art. 2). Operators must stay registered and keep filing returns, including VAT returns, during the suspension. The Prakas does not deregister them or relieve them of filing.
- Existing input VAT credits: The Prakas does not specify how credits carried forward from before 13 October 2026 are treated.
- Sector licensing: The Prakas does not replace the Ministry of Mines and Energy (MME) development permit required for EV charging stations.
Sources and references
• Ministry of Economy and Finance, Prakas No. 715 MEF.Prk.GDT on the Suspension of VAT on Electric Vehicle Charging Services, 13 October 2026 (Khmer) · GDT Prakas Register
• General Department of Taxation, FAQs on VAT on E-Commerce (10% VAT rate)
• Council for the Development of Cambodia, Taxation and Accounting
• Khmer Times, "Govt cuts import, export taxes to boost EVs, green energy"
How MLV Law Group can help
MLV Law Group advises green energy developers, infrastructure investors, commercial landlords and EV charging operators across Cambodia. Our corporate tax and energy practice provides comprehensive support on GDT VAT compliance, cost apportionment methodologies, site licensing agreements, revenue share contracts, and customs exemptions for clean energy technologies.
To discuss EV charging investments or tax structuring, contact Attorney at Law Mak Dane and our practice team at legal@mlvlawgroup.com or +855 71 777 4168. For related practice areas, see our expertise on Invest in Cambodia (QIP) and Company Formation.
Statutory Disclaimer
General information only, not legal advice. This note is based on Prakas No. 715 MEF.Prk.GDT as of 26 October 2026. Official Khmer texts prevail. An engagement letter is required before MLV Law Group acts on any matter.
