United States-Armenia Tax Treaty
Armenia International Tax Compliance Rules
Armenia- U.S. Tax Treaty Quick Summary
Armenia is located in Southwestern Asia—it borders, among other countries, Turkey and Iran. It’s economy is heavily dependent on agriculture with more than 35% of its labor force working in the farming sector.
Effective January 1, 2018, Armenia implemented its new Tax Code of Armenia. That code consolidates and codifies its tax laws into a single code and sets forth significant changes. Among the provisions are transfer pricing regulations, intangible amortization, permanent establishment provisions, loss carry forward rules, withholding requirements, and the removal of the Law on Presumptive Tax. Still further tax changes were implemented through acts in 2019 and 2020, which impact e-commerce, import and export transactions, non-resident dividends and VAT.
U.S.-Armenia Tax Treaty
Currency. Armenian dram (AMD).
Common Legal Entities. Joint stock company (open and closed), limited liability company, unlimited liability company, business partnership, sole entrepreneurship, cooperative, and branch.
Tax Authorities. The State Revenue Committee of Armenia.
Tax Treaties. Armenia is a party to more than 45 tax treaties. It is a signatory to the OECD MLI.
Corporate Income Tax Rate. 18%.
Individual Tax Rate. 23%.
Corporate Capital Gains Tax Rate. 18%.
Individual Capital Gains Tax Rate. 0% / 10% / 20% (applied to total sales proceeds).
Residence. An entity is a resident of Armenia if it is incorporated and located in Armenia. An individual is a resident of Armenia if he or she is present in the country for more than 183 days in the tax year, or if his or her center of vital interests is in Armenia.
Dividends. 5% (individual residents and nonresident companies and individuals) / 0% (resident companies).
Interest. 10% (individual residents and nonresident companies and individuals) / 0% (resident companies).
Royalties. 10% (individual residents and nonresident companies and individuals) / 0% (resident companies).
Transfer Pricing. Follows arm’s length principles and mainly follows OECD transfer pricing guidelines.
CFC Rules. No CFC rules.
Hybrid Treatment. No regulations relating to hybrids.
Inheritance/estate tax. No.
Other. Until December 31, 2024, income derived from the production of agricultural products is exempt from corporate income tax. In addition, income from the production of handmade carpets is exempt from corporate income tax.
Tax Treaty Network – International Tax Attorneys
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