Armenia

Payments to non-residents are subject to the following WHT rates:

• Payments for insurance, reinsurance, and transportation are subject to WHT at the rate of 5%.
• Interests, royalties, income from the lease of property, and capital gains (except capital gains from the sale of securities) are subject to WHT at the rate of 10%, and the dividends paid to non-residents are subject to WHT at 5% rate.
• Capital gains from the sale of securities are subject to WHT at the rate of 0%, and capital gains received by non-residents on sale of securities held in other organisations are taxed at 18% via WHT.
• Other income (from services) received from Armenian sources is subject to WHT at the rate of 20%.

WHT is required to be transferred to the budget not later than the 20th day following the quarter that includes the date of the income payment. A WHT return should be submitted by the 20th day following the reporting quarter.

WHT rates for non-residents may be reduced under a relevant tax treaty.

Notes

1. The direct ownership threshold for the 5% rate is 10%. The 15% rate applies in other cases.
2. The 0% rate applies to the sale on credit of industrial, commercial, and scientific equipment, and capital goods, and to interest on loans granted by banks. The 10% rate applies in other cases.
3. The 5% rate applies if the recipient company directly holds at least 100,000 United States dollars (USD) of the capital of the company paying dividends. The 10% rate applies in other cases.
4. The 5% rate applies if the recipient company directly owns at least 25% of the capital of the company paying dividends and the capital invested exceeds USD 100,000. The 15% rate applies in other cases.
5. The 5% rate applies if the beneficial owner is a company that directly owns at least 25% of the capital of the company paying dividends. The 10% rate applies in other cases.
6. The 0% rate applies if the recipient company directly or indirectly owns at least 25% of the capital of the company (during the latest two calendar years) paying dividends, provided that such dividends are tax exempt in the recipient company country. The 10% rate applies in other cases.
7. The 5% rate applies if the beneficial owner is a company that directly owns at least 25% of the capital of the company paying dividends. The 15% rate applies in other cases.
8. The 5% rate applies to royalties on copyright on software, trademark, model or project, industrial, commercial, scientific information (know-how) etc. The 10% rate applies to copyright royalties, including films, etc.
9. The 5% rate applies if the recipient company directly or indirectly holds at least 10% of the capital of the company paying dividends. The 15% rate applies in other cases.
10. The 0% rate applies to government debt and government-assisted debt. The 5% rate applies to interest on loans or credit granted by banks. The 10% rate applies in other cases.
11. The 5% rate applies to literary, artistic, or scientific work copyright royalties and to film and broadcasting royalties. The 10% rate applies in other cases.
12. The 0% rate applies to the credit sale of industrial, commercial, or scientific equipment, to the credit sale of merchandise or services, and to loans granted by a bank. The 10% rate applies in other cases.
13. The 5% rate applies to copyright royalties. The 10% rate applies in other cases.
14. The 5% rate applies to interest on loans or credit granted by banks. The 10% rate applies in other cases.
15. The 0% rate applies to interest on loans granted by banks. The 10% rate applies in other cases.
16. The 0% rate applies if the beneficial owner has invested at least 150,000 euros (EUR) in equity. The 5% rate applies in other cases.
17. The 5% rate applies if the recipient company directly holds at least 25% of the capital of the paying company. The 10% rate applies in other cases.
18. The 7% rate applies if the beneficial owner is a company (not partnership) that directly owns at least 25% of the capital of the company paying dividends. The 10% rate applies in other cases.
19. The ownership threshold for the 10% rate is 30%. The 15% rate applies in other cases.
20. The 10% rate applies if the beneficial owner is a company that directly owns at least 25% of the capital of the company paying dividends. The 15% rate applies in other cases.
21. The ownership threshold for the 0% rate is 25% (during the latest two calendar years), provided that such dividends are tax exempt in the recipient company country. The direct ownership threshold for the 5% rate is 10%. The 15% rate applies in other cases.
22. The 5% rate applies if the company receiving dividends has directly owned at least 10% of the capital (representing at least USD 100,000) of the company paying dividends for at least 12 months. The 10% rate applies in other cases.
23. The 5% rate applies if the capital invested by the company receiving the dividends exceeds USD 100,000. The 10% rate applies in other cases.
24. The ownership threshold for the 5% non-portfolio rate is 10%. The 0% rate applies if the dividends out of which the profits are paid have been effectively taxed at the normal rate for profits tax and the dividends are exempt income to the Dutch recipient. The 15% rate applies in other cases.
25. The ownership threshold for the 0% rate is 25% (during the latest two calendar years), provided that such dividends are tax exempt in the recipient company country. The 10% rate applies in other cases.
26. The 5% rate applies if the recipient company directly holds at least 25% of the capital of the paying company and the capital invested exceeds 200,000 Swiss francs (CHF). The 15% rate applies in other cases.
27. The 5% rate applies if the recipient company directly or indirectly owns at least 25% of the capital of the company paying dividends and the capital invested is at least 1 million pound sterling (GBP). The 15% rate applies to the income derived directly or indirectly from immovable property by an investment that distributes most of this income annually and income from such immovable property is exempted from tax. The 10% rate applies in other cases.
28. The 5% rate applies if the beneficial owner is a company (not partnership) that directly owns at least 10% of the capital of the company paying dividends. The 10% rate applies in other cases.
29. The 0% rate applies to government debt and government-assisted debt. The 10% rate applies in other cases.
30. The ownership threshold for the 0% rate is 25% (during the latest two calendar years), provided that such dividends are tax exempt in the recipient company country. The ownership threshold for the 5% rate is 10%. The 15% rate applies in other cases.