Tax in Armenia

Who is the tax authority and where do filings live?

Armenia's State Revenue Committee (Petakan ekamutneri komite, SRC) under the Government of Armenia is the tax and customs authority [SC1]. Filings flow through e-Filing electronic services. Tax disputes proceed through SRC internal review, the Tax Disputes Commission, and the administrative courts. The credentialed Armenian tax-and-accounting professions are CPA Armenia regulated by the Chamber of Auditors. Substantive law: Tax Code of the Republic of Armenia (codified single statute since 2018), Customs Code, and successive amendment laws. Armenia is a member of the Eurasian Economic Union (EAEU) Customs Union (with Russia, Kazakhstan, Belarus, Kyrgyzstan), creating a regional trade-and-tax-coordination framework. Armenia is also a CSTO member and has positioned itself as a regional tech hub leveraging the post-2020 Karabakh War economic-diversification programme.

What is the tax year and when are returns due?

The individual tax year is the calendar year. Personal annual returns are due 1 May of the year following the tax year [SC1]. Wage earners' income tax is fully withheld monthly by employers. Corporate fiscal years align with the calendar year (with limited exception); annual corporate income tax returns are due 20 April. Quarterly advance corporate tax instalments apply for taxpayers above specified annual revenue thresholds. AAH (VAT) returns are filed monthly by the 20th of the following month under the standard regime. Withholding tax (WHT) returns are filed monthly. Annual financial statements are required for in-scope corporations.

Who is an Armenian tax resident?

Under the Tax Code of Armenia, an individual is tax resident in Armenia if (a) being physically present in Armenia for at least 183 days in a 12-month period, OR (b) maintaining their centre of vital interests in Armenia [SC2]. Residents are taxed on worldwide income; non-residents on Armenian-source income at flat or schedular rates (typically 20 percent on most categories with treaty rates applying). Treaty residency tie-breakers under Armenia's bilateral DTC network apply where two jurisdictions both treat a person as resident. PE attribution under Armenia treaty network and domestic Tax Code follows OECD Model definitions. Tax Residency Certificate procedure under SRC provides foreign-residency-certificate counterparts.

What are the personal income tax rates?

Flat 20 percent on most categories of personal income (post-2020 reform reducing progressively from 23 percent earlier — a major taxpayer-positive change as part of the post-Velvet-Revolution reform agenda) [SC1]. Investment income (dividends from Armenian companies) face 5 percent withholding (final). Interest from Armenian financial institutions to individuals faces 10 percent withholding (final). Capital gains face 20 percent flat under specific provisions. Mandatory pension contributions add 5 percent (employee-side, post-2018 mandatory pension scheme) plus state-matching component. Specific deductions include qualifying medical expenses and certain other categories. Salaried employees have most obligations satisfied through monthly employer-side withholding.

How does Armenia's corporate tax work?

The corporate income tax rate is 18 percent flat on Armenian-source taxable profit [SC2]. SMEs may elect a simplified turnover-based regime under specific eligibility conditions including annual turnover thresholds. Free Economic Zones provide tax holidays for licensed export-manufacturing operations. The IT-sector tax incentive framework provides reduced rates for qualifying IT-services exporters under successive amendments. Withholding tax on dividends to non-residents is 5 percent (treaty rates apply); royalties 10 percent default; technical-services 10 percent default; interest 10 percent default. Pillar Two implementation has not yet been formally transposed; in-scope MNE groups should monitor for legislative developments. Tax loss carryforwards: 5 years; carryback unavailable. Transfer pricing under the Tax Code follows OECD principles with documentation requirements progressively expanded.

What about AAH (VAT)?

The standard AAH rate is 20 percent under the Tax Code [SC3]. Zero-rated supplies include exports of goods and services. Exempt supplies include healthcare, education, financial services (under specific definitions), residential rental, and several other social-policy categories. Registration threshold is AMD 115 million annual turnover. Reverse-charge mechanism applies on imported services. Foreign-supplier registration for B2C cross-border digital services applies under successive amendments. Excise Tax applies on alcohol, tobacco, fuels, and specified other goods. Customs-VAT on imports collected at the border. Bad-debt VAT relief is available under specific conditions.

How are cryptoassets taxed?

Armenia has not enacted dedicated cryptoasset taxation. Central Bank of Armenia advisory positions cryptoassets as not legal tender [SC2]. Where declared, gains under existing investment-income or capital-gains categories at 20 percent flat. Mining and staking conducted in Armenia are business income at corporate rates. Armenia's Tumo Center and broader IT-sector growth has driven significant blockchain-related activity without formalised tax framework. Dedicated CASP licensing remains pending parliamentary action. Receipt of crypto as employment compensation is taxable under standard PIT framework with AMD-equivalent value at receipt. NFTs and stablecoins fall under the same case-by-case treatment.

What is the treaty network and what are the audit triggers?

Armenia has approximately 50 active double tax treaties [SC4]. The treaty network covers Russia, Iran, Georgia, Belarus, Kazakhstan, Ukraine, Moldova, Lithuania, Latvia, Estonia, Poland, Czech Republic, Slovakia, Hungary, Romania, Bulgaria, Germany, France, Italy, Spain, Netherlands, Switzerland, Austria, Belgium, UK, Greece, Cyprus, Sweden, Finland, Norway, Israel, Turkey (substantively constrained by bilateral relations), Lebanon, UAE, Saudi Arabia, Kuwait, China, India, Indonesia, Vietnam, Thailand, Singapore, Pakistan, and several other counterparties. Armenia signed the OECD MLI on 7 June 2017 with successive ratification status. Audit triggers include: disproportionate VAT credits relative to declared output; transfer-pricing non-compliance; undeclared bank deposits flagged via expanding CRS exchanges (Armenia adopted CRS framework under successive amendments); and the post-2020 Karabakh War recovery compliance regime. Standard SOL is 5 years from the tax year; extended for fraud or non-filing.

What are the common penalties and pitfalls for foreigners?

The Armenian penalty framework under the Tax Code imposes administrative-fine sanctions for late filings, failure to file, incorrect declarations (50 percent surcharge for ordinary cases; up to 100 percent for fraudulent), and failure to maintain accounting records [SC5]. Default interest accrues at the prevailing Central Bank refinancing rate plus statutory margin on unpaid tax. Tax-evasion criminal exposure under the Criminal Code carries fines and imprisonment for grossly-significant evasion. Common foreign-national pitfalls: (1) the EAEU Customs Union framework creates regional indirect-tax coordination affecting cross-border supply flows; (2) the post-2020 Karabakh War recovery and economic-diversification programme has driven progressive fiscal-policy reforms — practitioners should track regulatory developments; (3) the centre-of-vital-interests test creates broad domiciliary-tax-attachment for individuals with substantial Armenian connections; (4) Pillar Two has not yet been transposed but in-scope MNE groups should monitor for developments; (5) Free Economic Zones tax-holiday frameworks have specific compliance requirements; (6) IT-sector tax incentives have specific eligibility conditions; (7) the post-2018 mandatory pension scheme (5 percent employee + state-matching) creates payroll-cost dynamics; (8) cross-border digital-services VAT framework progressively expanded; (9) cryptocurrency activity remains in regulatory ambiguity pending CASP-licensing-framework parliamentary action; and (10) treaty MLI modifications introduce PPT and other anti-abuse rules where applicable.