There are no group taxation provisions available in Armenia.
The transfer pricing regulations entered into force on 1 January 2020 under the Tax Code. This will have a significant impact on many taxpayers, as previously there was no transfer pricing legislation in Armenia.
The new regulations define the scope of transfer pricing control, introduce the arm’s-length principle and transfer pricing methods, define sources of information for analysing transfer pricing, determine transfer pricing documentation requirements, and establish other important provisions.
Overview of the transfer pricing regulations
The new rules are aimed at transactions between related parties and transactions with tax havens. They will apply to the taxpayers whose sum of controlled transactions exceed AMD 200 million in any reporting year.
For application of the transfer pricing rules, Armenian tax authorities will focus on completeness of calculation and payment of the following taxes:
- Mineral royalty tax (for the use of metal mineral resources).
Transfer pricing documentation on controlled transaction shall be submitted to the tax authorities no later than 20 April of the year following the tax period.
Taxpayers shall submit the documents containing detailed descriptions of the controlled transactions with related parties and applied method of analysis to the tax authority within 30 working days following the day of receipt of the written notification sent in by the taxpayer.
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.