There are no group taxation provisions available in Armenia.
The transfer pricing regulations entered into force on 1 January 2020. It defines the concept of transfer pricing, methods, comparability factors, documentation procedures, and sources of information about uncontrolled and controlled transactions.
Overview of the transfer pricing regulations
Transfer pricing rules apply to transactions between related parties that are controlled and if the amount of all controlled transactions carried out by the taxpayer during the tax year exceeds AMD 200 million (net of VAT, excise tax, and environmental tax).
The tax authorities check the compliance of controlled transactions with the principle of market relations, as well as the completeness of the calculation and payment of CIT and payment for the use of mineral resources (royalty).
If the amount of all controlled transactions during the tax year exceeds the threshold of AMD 200 million, the taxpayer must submit a notification of controlled transactions to the tax authorities no later than 20 April of the year following the tax period.
Taxpayers must submit documentation on control transactions to the tax authority within 30 working days from the date of receipt of the written notification.
Armenia does not have thin capitalisation rules. However, there are certain limitations on deductibility of interest expenses (see Interest expenses in the Deductions section).
Controlled foreign companies (CFCs)
There are no CFC rules in Armenia.