When a non-resident company conducts business in Armenia through a subdivision (i.e. a branch or a representative office) and maintains separate accounting records for that subdivision, taxable income generally should be determined on the same basis as for resident entities. Note that a subdivision is taxable on dividends received from Armenian companies.
The non-resident taxpayers conducting activity in Armenia through subdivision (i.e. PE) should keep separate accounting books.
The income received by a non-resident entity conducting activity in Armenia through a PE is considered income received by the PE if the supporting documents of income received are issued in the name of the PE.
Armenia has no special tax rules for non-commercial representative offices established to engage in liaison-type activities. Such offices are subject to the normal CIT, but an exemption from CIT may be available under a relevant tax treaty if the activities of the representative office are not sufficient to constitute a PE for the foreign entity.
See the Withholding taxes section for a list of countries with which Armenia has a tax treaty.