Legal and Tax Updates

Issue: No. 008P/25 – 23 June 2025

On 16 June 2025, the Ministry of Land Management, Urban Planning and Construction (the “MLMUPC“) issued Instruction No 001 on the Construction of Telecommunication Infrastructure in Populated Area, Residential Zone, Housing Development, Co-owned Building, Commercial Building, Shopping Mall, Industrial Zone, Special Economic Zones, and other designated area or building. (the “Instruction“).

This Instruction provides technical guidance to construction project owners, Borey developer, and investors in industrial zone, special economic zone, and tourism zone. Its objective is to promote investment efficiency, enhance construction quality, ensure public safety, support environmental preservation, and facilitate the development of reliable telecommunications services.

Key Requirements:

1. Antenna station construction

Developers must allocate land for the construction of antenna stations within Borey development, industrial zone, special economic zone, tourism zone, and other designated areas. The required land size depends on the scale of the project and must be either:

• 25 m² or 1.5m x 1.5m
• 12 m² or 2m x 6m or 3m x 4m

2. Installation of In-Building Solution (IBS) System

In commercial building, co-owned building, shopping mall, and similar structure, a dedicated room must be allocated for telecommunication equipment and infrastructure. The room must have a minimum size of 12 m² or 2m x 6m or 3m x 4m.

3. Construction of Telecommunication Cable Network Infrastructure

Developers are required to install a complete telecommunication cable network that:

• Connects the antenna station to the broader mobile network
• Connects to the last-mile network (e.g., fiber termination boxes for FTTH services)

The network must support both mobile and fixed-line services and be designed  to allow users to switch between internet service providers without requiring additional infrastructure connection.

Disclaimer

The article is merely for general information purposes. It does not constitute a legal advice on the subject matter. If you have any questions or need any assistance, please feel free to contact us:

	NOEUM Sokvichhai, Partner, Managing Director sokvichhai.noeum@sithisak-lawoffice.com +855 12 826 785	Mr. Sokvichhai has more than 8 years of experiences in labour, corporate, commercial and investment advisory in Cambodia. He actively advices and assists various businesses in commercial, tax, and labour registration, business licensing, products registration & distribution, business recapitalization & restructuring, and mergers & acquisitions transaction. He also has particular experiences in advising collective investment fund and trust business, initial public offering, bond issuance, investment incentives & qualified investment project, and labour & employment related issues. Sokvichhai also assists major business in preparing various complex commercial agreements.
	Dr. CHHAK Limchheang, Partner, Head of Real Estate and Construction Practice Group limchheang.chhak@sithisak-lawoffice.com +855 89 813 160	He has several years of professional experiences in real estate-related transaction and construction sector in Cambodia. He has advised local and foreign clients on acquisition and disposal of residential, industrial and commercial properties, on commercial lease, factory perpetual lease, real estate joint venture development and FIDIC agreements. Recently, he led counsel to advise on both real estate and tax issues of real estate development project with an approximate investment portfolio of USD 40 million in Kampot Province. He is currently leading a legal counsel to advise a major domestic company in their joint venture property development with an investment portfolio nearly USD 200 million in Phnom Penh.

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