{"id":149422,"date":"2026-10-08T10:33:11","date_gmt":"2026-10-08T10:33:11","guid":{"rendered":"https:\/\/www.legal500.com\/guides\/?post_type=comparative_guide&#038;p=149422"},"modified":"2026-10-09T12:43:05","modified_gmt":"2026-10-09T12:43:05","slug":"armenia-tax","status":"publish","type":"comparative_guide","link":"https:\/\/www.legal500.com\/guides\/chapter\/armenia-tax\/","title":{"rendered":"Armenia: Tax"},"content":{"rendered":"","protected":false},"template":"","class_list":["post-149422","comparative_guide","type-comparative_guide","status-publish","hentry","guides-tax","jurisdictions-armenia"],"acf":[],"appp":{"post_list":{"below_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Concern Dialog Law Firm<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/www.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/07\/logo-eng.png\"\/><\/span><\/div>"},"post_detail":{"above_title":"<div class=\"guide-author-details\"><span class=\"guide-author\">Concern Dialog Law Firm<\/span><span class=\"guide-author-logo\"><img src=\"https:\/\/www.legal500.com\/guides\/wp-content\/uploads\/sites\/1\/2019\/07\/logo-eng.png\"\/><\/span><\/div>","below_title":"<span class=\"guide-intro\">This country specific Q&amp;A provides an overview of Tax laws and regulations applicable in Armenia<\/span><div class=\"guide-content\"><div class=\"filter\">\r\n\r\n\t\t\t\t<input type=\"text\" placeholder=\"Search questions and answers...\" class=\"filter-container__search-field\">\r\n\t\t\t<\/div>\r\n\r\n\t\t\t\r\n\r\n\r\n\t\t\t<ol class=\"custom-counter\">\r\n\r\n\t\t\t\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How often is tax law amended and what is the process?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>In Armenia, tax law is amended very often (e.g. in 2026 the Tax code of the Republic of Armenia has been amended 6 times). The Tax Code is the law in Armenia that undergoes the most frequent amendments. The process is as follows: A draft law proposing amendments can be initiated by authorized actors, including the Government, members of the National Assembly, parliamentary factions in accordance with the applicable rules. The proposal is submitted to the National Assembly with the required supporting documents. The author of the draft law organizes a public hearing by publishing it on the official <a href=\"http:\/\/www.e-draft.am\"><strong>www.e-draft.am<\/strong><\/a> website. Any person may visit the website and submit comments, proposals, or objections regarding the draft. The public hearing period is at least 15 days.<\/p>\n<p>At the same time, the draft is sent to the relevant ministries for review. It is then discussed by the appropriate committees of the Government. If the draft receives favorable opinions, it is submitted for consideration by the Government, which then decides whether to submit it to the National Assembly.<\/p>\n<p>The draft is registered and assigned to an appropriate parliamentary commision. The draft is debated in the National Assembly in first reading. In case of amendments and proposals the competent committee considers them and prepares the draft for the next hearing. The revised draft is debated in second reading. The National Assembly then votes on the bill. For an ordinary law, the required voting threshold for tax laws is\u00a0 a majority of the deputies participating in the vote, provided that more than half of the total number of deputies participate..<\/p>\n<p>Once the National Assembly adopts the law, the Chairperson of the National Assembly sends it to the\u00a0President of the Republic. The President signs and promulgates the law within the constitutionally prescribed period or may use the available constitutional procedure concerning its constitutionality.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the principal administrative obligations of a taxpayer, i.e. regarding the filing of tax returns and the maintenance of records?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The taxpayer (tax agent) and its official shall be obliged to:<\/p>\n<p>1) Unless otherwise provided by Tax Code, independently calculate and fulfill its tax obligations in accordance with the procedure and within the time limits established by Tax Code and the laws of the Republic of Armenia on payments, also making tax and (or) payment prepayments in the cases and in the manner established by Tax Code and the laws of the Republic of Armenia on payments.<\/p>\n<p>2) maintain records established by Tax Code and the laws of the Republic of Armenia on payments, and in the cases established by the legislation, also keep accounting records.<\/p>\n<p>3) submit tax calculations to the tax authority in accordance with the procedure and within the time limits established by Tax Code and the laws of the Republic of Armenia on payments.<\/p>\n<p>4) submit documents confirming its right to tax privileges.<\/p>\n<p>5) ensure the preservation of documents necessary for calculating the tax base and submitting tax calculations, documents substantiating the amount of income received or expenses incurred, and taxes paid (withheld) for a <strong>period of no less than five years<\/strong>, starting from the reporting period to which these documents relate.<\/p>\n<p>6) provide copies of accounting documents filled out (compiled) in languages \u200b\u200bother than Russian and English with their Armenian translations, without notarization.<\/p>\n<p>7) at each address of its activity, in the most visible place (and at the places of location and (or) adoption of management decisions, operational financial management &#8211; on appropriate signs), post a statement in the form established by the tax authority, indicating the full name of the taxpayer (in the case of individual entrepreneurs &#8211; the name, surname, patronymic of the individual), the taxpayer&#8217;s registration number, the address of the given place of activity and the type (types) of activity carried out at the given address.<\/p>\n<p>8) ensure working conditions for the implementation of tax control, including providing officials carrying out tax control with the documents, data and other information necessary for the calculation and payment of a tax or fee, their photocopies (the costs of photocopying are borne by the tax authority) or duplicates. In the event of failure to provide the documents, data and other information provided for in this clause during the tax audit, the said documents, data and information, as favorable factual circumstances, cannot be presented as evidence in the administrative act, in the administrative or judicial appeal proceedings, and the taxpayer (tax agent) bears the risk of negative consequences conditioning the outcome of the case due to their absence, if he does not present sufficient justifications that he was objectively deprived of the opportunity to present the said evidence during the administrative proceedings. In the case provided for in this clause, if tax liabilities have been imposed as a result of the tax audit, then the obligation (burden) of proving the liabilities imposed as a result of the taxpayer&#8217;s failure to provide documents, information and data that would have favorable consequences for him during the administrative proceedings in the administrative or judicial appeal proceedings cannot be placed on the tax authority.<\/p>\n<p>9) Upon written request of officials conducting a comprehensive tax audit, provide an electronic copy of the file created using the accounting computer program (for the period covered by the audit assignment).<\/p>\n<p>10) not to obstruct the performance of official duties of officials conducting tax audit, fulfill their lawful requirements.<\/p>\n<p>11) appoint (authorize) officials to replace them in order to perform their duties during their absence.<\/p>\n<p>12) in case of disagreement with the facts of acts, protocols and their drafts, references and administrative acts drawn up as a result of tax audit and failure to sign them, make an appropriate note about this in the aforementioned documents.<\/p>\n<p>13) after receiving state registration (registration), submit to the tax authority, up to and including the last day for submitting tax calculations for the first reporting period, as provided for by the Code, and in case the Code stipulates a mandatory requirement to submit the documents specified in the Code electronically and an agreement has been signed with the tax authority on the electronic submission of tax calculations, fill in the &#8220;Personal Office&#8221; section of the tax authority&#8217;s electronic management system for submitting tax reports, the e-mail address to which the tax authority will send notifications electronically within the framework of the administration carried out by the tax authority in cases provided for by the Code.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Who are the key tax authorities? How do they engage with taxpayers and how are tax issues resolved?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The main tax authority in the Republic of Armenia is State Revenue Committee (SRC). The SRC is the state body responsible for tax and customs administration. The SRC not only is responsible for service provisions to the taxpayers, but also for tax control and enforcement of tax responsibility. Tax issues can be resolved by the SRC via hotline, electronic portal and official clarification mechanisms.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are tax disputes heard by a court, tribunal or body independent of the tax authority? How long do such proceedings generally take?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Tax disputes can be heard by the Tax Authority&#8217;s Appeals Commission \u0585r by a court (the Administrative court of the Republic of Armenia). Because of the workload of the courts the proceedings generally take long (more than 2 years).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the typical deadlines for the payment of taxes? Do special rules apply to disputed amounts of tax?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The deadlines for the tax payments depend on the tax type. The profit tax (for legal entities) is to be paid every year until April 20, the VAT is to be paid monthly, by the 20th day of the following month, deadline for income tax withheld by a tax agent is by the 20th day of the following month and for turnover tax \u2013 by the 20th of every trimester.<\/p>\n<p>An individual shall pay the amount of income tax by <strong>July 1 of the following year\u2024<\/strong><\/p>\n<p>When the tax amounts are disputed the tax payment is suspended and the payment is made within 10 days from the moment the administrative act becomes final.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are tax authorities subject to a duty of confidentiality in respect of taxpayer data?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. According to the Tax Code of the Republic of Armenia, any information received by a tax authority or tax servant regarding a taxpayer, taxpayer\u2019s activities is considered a tax secrecy, except for:<\/p>\n<p>a. information published by the taxpayer or with his consent,<\/p>\n<p>b. information on the taxpayer\u2019s registration number,<\/p>\n<p>c. information included in the taxpayer\u2019s charter,<\/p>\n<p>d. information on violations of the requirements of legal acts regulating tax relations and applied liability measures,<\/p>\n<p>e. information submitted to tax or customs authorities of other states on the basis of international or interdepartmental agreements (agreements) regarding the taxpayer or taxpayer\u2019s activities, in case of submission to such authorities,<\/p>\n<p>f. information on the number of employees declared by the taxpayer during the reporting month on the basis of labor and civil law contracts,<\/p>\n<p>g. information on liabilities repaid through a single account or a single account of an administrative act, as well as information on the repayment of outstanding liabilities in terms of taxes, payments and state duties through a single account or a single account of an administrative act,<\/p>\n<p>h. information on the taxpayer&#8217;s taxation system, information subject to publication.<\/p>\n<p>The tax authority is obliged to maintain tax secrecy. It is allowed to be used only by the competent authorities for the purposes specified by law.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is this jurisdiction a signatory (or does it propose to become a signatory) to the Common Reporting Standard?  Does it maintain (or intend to maintain) a public register of beneficial ownership?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. The Republic of Armenia signed the Convention on Mutual Administrative Assistance in Tax Matters on January 24, 2018, including subsequent amendments, and the Multilateral Agreement of Competent Authorities on Automatic Exchange of Financial Account Information on January 12, 2024, including subsequent amendments.<\/p>\n<p>Armenia also maintains a public register of ultimate beneficial owners, and the competent authority for the register is the State Register of Legal Entities\u2024<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the tests for determining residence of business entities (including transparent entities)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>A resident organization of the Republic of Armenia (hereinafter referred to as a resident organization) is an organization which is located is the Republic of Armenia. A non-resident organization of the Republic of Armenia (hereinafter referred to as a non-resident organization) is an organization that is not considered a resident organization.<\/p>\n<p>The location of an organization is the place of state registration of the organization (in the case of an institution, the place of state registration).<\/p>\n<p>The location of an investment fund registered in accordance with the procedure established by the legislation of the Republic of Armenia is the location of the fund manager.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Do tax authorities in this jurisdiction target cross border transactions within an international group? If so, how?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Armenian tax authorities target cross-border transactions within international groups, primarily through transfer-pricing controls. They require qualifying related-party transactions to comply with the arm&#8217;s-length principle and, above the applicable threshold, require annual notification of controlled transactions. The SRC may review the pricing and supporting documentation and adjust the Armenian tax base where the transactions do not comply with the applicable rules. Cross-border payments are also subject to other rules, including withholding tax and permanent-establishment provisions.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a controlled foreign corporation (CFC) regime or equivalent?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There are no controlled foreign corporation rules.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a transfer pricing regime?  Is there a \"thin capitalization\" regime?  Is there a \"safe harbour\" or is it possible to obtain an advance pricing agreement?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Armenia has a transfer-pricing regime, effective from 1 January 2020. The rules apply to controlled transactions between related parties and require compliance with the arm\u2019s-length principle. Where the aggregate value of controlled transactions exceeds AMD 200 million in a tax year (excluding VAT, excise tax and environmental tax), the taxpayer is generally required to notify the tax authority and maintain supporting transfer-pricing documentation.<\/p>\n<p>Armenia does not have a general thin capitalization regime. However, there are restrictions on the deductibility of interest expenses that can affect the tax treatment of intra-group financing.<\/p>\n<p>There is no general transfer-pricing safe-harbour regime. However, an Advance Pricing Agreement (APA) regime became effective from 1 January 2024. A taxpayer may seek an APA with the State Revenue Committee concerning the transfer-pricing methodology applicable to qualifying transactions with related non-resident parties. APAs can provide prospective certainty regarding the applicable pricing methodology. A taxpayer may apply to the tax authority for a Advance Pricing Agreement regarding transactions with a non-resident related party(ies).<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a general anti-avoidance rule (GAAR) and, if so, how is it enforced by tax authorities (e.g. in negotiations, litigation)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Armenia does not have a general, standalone anti-avoidance rule (GAAR) in the traditional sense. However, the Tax Code contains various specific anti-avoidance provisions, including transfer-pricing rules, rules concerning the determination of taxable income and deductible expenses, and provisions addressing transactions that do not reflect their actual economic circumstances.<\/p>\n<p>The SRC may apply these rules during tax audits and other forms of tax control and may assess additional tax, penalties and interest where a taxpayer has incorrectly determined its tax liability.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is there a digital services tax? If so, is there an intention to withdraw or amend it once a multilateral solution is in place?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. Armenia does not currently impose a separate Digital Services Tax.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How has the BEPS 2.0 two-pillar approach been implemented in your jurisdiction (or plans for implementation)<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Armenia has implemented a number of the OECD\/G20 BEPS measures (TP, CbC reporting, BEPS Multilateral Instrument, tax transparency) but has not yet implemented the BEPS 2.0 Two-Pillar Solution through a domestic Pillar One or Pillar Two regime.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">How has the OECD BEPS program impacted tax policies?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>The OECD BEPS program has had a significant impact on Armenian tax policy, particularly in relation to international tax transparency, transfer pricing, treaty abuse and the taxation of multinational groups. Armenia has progressively incorporated several of the BEPS minimum standards into its domestic legislation and international tax framework.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Does the tax system broadly follow the OECD Model i.e. does it have taxation of: a) business profits, b) employment income and pensions, c) VAT (or other indirect tax), d) savings income and royalties, e) income from land, f) capital gains, g) stamp and\/or capital duties? If so, what are the current rates and how are they applied?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes.<\/p>\n<p>a. business profit tax (18%),<\/p>\n<p>b. employment income tax (20%),<\/p>\n<p>c. VAT (20%),<\/p>\n<p>d. royalties (10%, and interest (if not exempt) &#8211; 20%),<\/p>\n<p>e. real estate tax &#8211; it should be specified whether a transaction is being done to the land or not. If the land is being sold or given for rent, it is subject to income tax. If there are no transactions concerning the land, it is subject to real estate taxation. Armenia imposes property tax on immovable property and land located in Armenia. The tax applies to buildings, apartments, houses and land. Property tax is generally a local tax administered by municipalities rather than by the State Revenue Committee.<\/p>\n<p>f. capital gains \u2013 there is no standalone capital gain tax. For corporate taxpayers, capital gains are generally included in taxable profit and are subject to the applicable profit tax rate (generally 18%). For individuals, income from the alienation of property is generally subject to income tax, with a general rate of 10%, although specific exemptions and rates apply depending on the asset and circumstances of the disposal. Special rules apply to non-residents, including gains from Armenian-source assets and securities.<\/p>\n<p>g. stamp duties (military fee) (1,000 AMD for salaries up to 1,000,000 AMD; 15,000 AMD above).<\/p>\n<p>There is no savings income tax, capital gain tax, inheritance, gift, pension or wealth tax.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is business tax levied on, broadly, the revenue profits of a business computed in accordance with accounting principles?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes, the business profit tax is broadly based on the revenue profits of a business.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are common business vehicles such as companies, partnerships and trusts recognised as taxable entities or are they tax transparent?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>According to the Tax Code, RA resident and non-resident natural persons, RA resident and non-resident organizations, the permanent establishment of a non-resident organization or a non-resident natural person are considered tax-paying entities.<\/p>\n<p>The tax exemption is provided as a tax benefit by the Tax Code of the Republic of Armenia.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is liability to business taxation based on tax residence or registration?  If so, what are the tests?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Liability to Armenian business taxation is based on residence\/location rather than merely on tax registration. An organisation is considered an Armenian tax-resident organisation if it is located in Armenia. Under the Tax Code, an organisation&#8217;s location is generally the place of its state registration. Armenian resident organisations are generally subject to Armenian profit tax on their taxable profit.<\/p>\n<p>A non-resident organisation is not generally treated as an Armenian resident merely because it is registered as a taxpayer in Armenia. However, a non-resident may become subject to Armenian taxation where it carries on business in Armenia through a permanent establishment (PE) or derives Armenian-source income subject to Armenian tax.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any favourable taxation regimes for particular areas (e.g. enterprise zones) or sectors (e.g. financial services)?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>There are general and special taxation systems in the Republic of Armenia.<\/p>\n<p>Within the framework of the general taxation system, organizations, individual entrepreneurs and notaries are taxed, in particular, by VAT and (or) profit tax.<\/p>\n<p>The special taxation systems are:<\/p>\n<p>1) <strong>turnover tax system<\/strong>: within the framework of the turnover tax system, organizations are taxed by turnover tax replacing VAT and (or) profit tax, and individual entrepreneurs are taxed by profit tax and turnover tax replacing VAT. The following persons and entities may not be considered turnover tax payers: banks, credit organizations, insurance companies, insurance agents, insurance brokers, persons providing services involving crypto-assets as defined by the Law on Crypto-Assets, investment companies, specialized participants of the securities market, pawnshops, persons engaged in foreign currency purchase and sale activities, investment funds, fund managers, payment and settlement organizations, persons engaged in organizing casinos, games of chance, totalizators and online totalizators, persons engaged in organizing lotteries, notaries, audit firms, and persons providing legal services.<\/p>\n<p>A resident commercial organization and individual entrepreneur whose sales turnover for all types of activities during the previous tax year did not exceed 115 million drams may be considered a turnover tax payer.<\/p>\n<p>2) <strong>micro-entrepreneurship system<\/strong>: within the framework of the micro-entrepreneurship system, organizations and individuals are exempted from taxation, in particular, by VAT and (or) profit tax, as well as turnover tax.<\/p>\n<p>Some sectors such as provision of made-to-order household, clothing and footwear manufacturing and repair services to individuals, language, dance and singing instruction, educational and extracurricular activities in the fields of physical education and sports, as well as other related services fall under provisions of micro-entrepreneurship system.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any special tax regimes for intellectual property, such as patent box?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Income derived or receivable from the use of a taxpayer&#8217;s intellectual property and other non-property rights is considered to be royalties.<\/p>\n<p>Royalties are income for the use of, in particular, any invention, patent, copyright of literature, science or art, including cinematograph films for television or radio broadcasting, audio and video recordings, computer programs, certificate, trademark, plan or model, scheme, secret formula or process, or industrial, commercial or scientific information or experience.<\/p>\n<p>Royalties paid to non-residents are generally subject to 10% withholding tax in Armenia. The rate may be reduced under an applicable double tax treaty. Royalties received by Armenian individuals are also generally subject to a 10% income tax rate.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is fiscal consolidation permitted? Are groups of companies recognised for tax purposes and, if so, are there any jurisdictional limitations on what can constitute a tax group? Is there a group contribution system or can losses otherwise be relieved across group companies?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>No. Armenia does not permit fiscal consolidation or tax consolidation for groups of companies. Armenian tax legislation does not recognize a group of companies as a single taxpayer for corporate income tax purposes, and there is no group contribution system allowing profits and losses to be offset between group companies. Each company is generally taxed separately on its own taxable income. However, Armenian tax legislation envisages transfer pricing rules so if the legal prerequisites are present the TP rules will be applied.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any withholding taxes?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Armenia operates a withholding tax regime. Payments of Armenian-source income to non-residents are generally subject to withholding at source, with rates of 5% for dividends, 10% for interest, royalties and rental income, and 20% for certain other Armenian-source services. A 5% rate applies to certain insurance, reinsurance and transportation income, while certain securities-related capital gains are subject to a 0% rate. Applicable double tax treaties may reduce the domestic rates.<\/p>\n<p>The Armenian payer\/tax agent generally has to remit the withheld tax to the state budget\u00a0by the 20th day following the quarter in which the payment was made, and submit the relevant WHT return by the same deadline.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Are there any environmental taxes payable by businesses or environmental tax credits available to businesses?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Environmental tax is a tax paid to the state budget in order to generate the necessary funds for the implementation of environmental measures.<\/p>\n<p><strong>1. The objects of taxation under the environmental tax are:<\/strong><\/p>\n<p>1) emission of harmful substances into the atmosphere.<\/p>\n<p>2) leakage of harmful substances and (or) compounds into water resources.<\/p>\n<p>3) subsoil use, production and (or) consumption waste:<\/p>\n<p style=\"padding-left: 40px\">a. placement in specially designated places,<\/p>\n<p style=\"padding-left: 40px\">b. storage in specially designated places.<\/p>\n<p>4) goods that cause harm to the environment:<\/p>\n<p style=\"padding-left: 40px\">a. import into the territory of the Republic of Armenia,<\/p>\n<p style=\"padding-left: 40px\">b. alienation by importers-sellers and (or) producers-sellers in the territory of the Republic of Armenia.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">Is dividend income received from resident and\/or non-resident companies taxable?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Yes. Dividend income received by both a resident and a non-resident, is taxable by income tax at the rate of 5%.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\t\t\t\t\t<li class=\"question-block filter-container__element\">\r\n\t\t\t\t\t\t<h3 class=\"filter-container__match-html\">What are the advantages and disadvantages offered by your jurisdiction to an international group seeking to relocate activities?<\/h3>\r\n\t\t\t\t\t\t<button id=\"show-me\">+<\/button>\r\n\t\t\t\t\t\t<div class=\"question_answer filter-container__match-html\" style=\"display:none;\"><p>Armenia offers a number of advantages for international groups considering relocating business activities, particularly in technology, high-tech, services and certain manufacturing activities. The standard corporate income tax rate is 18%, and Armenia provides targeted tax incentives for qualifying activities, including free economic zones and high-tech activities.<\/p>\n<p>The key advantages are the free economic zone regimes (for EAEU countries), relatively moderate corporate income tax rate etc. Potential disadvantages include legislation relative instability and absence of a group taxation regime, the resolution of tax disputes may take <strong>two years or more<\/strong>.<\/p>\n<\/div>\r\n\r\n\r\n\t\t\t\t\t<\/li>\r\n\r\n\t\t\t\t\r\n<div class=\"word-count-hidden\" style=\"display:none;\">Estimated word count: <span class=\"word-count\">3932<\/span><\/div>\r\n\r\n\t\t\t<\/ol>\r\n\r\n<script type=\"text\/javascript\" src=\"\/wp-content\/themes\/twentyseventeen\/src\/jquery\/components\/filter-guides.js\" async><\/script><\/div>"}},"_links":{"self":[{"href":"https:\/\/www.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide\/149422","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.legal500.com\/guides\/wp-json\/wp\/v2\/comparative_guide"}],"about":[{"href":"https:\/\/www.legal500.com\/guides\/wp-json\/wp\/v2\/types\/comparative_guide"}],"wp:attachment":[{"href":"https:\/\/www.legal500.com\/guides\/wp-json\/wp\/v2\/media?parent=149422"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}