Armenia corporate and personal cross-border preparation

Who this applies to

Use this Guide for ordinary corporate 2026 cross-border receipts/payments and associated residence evidence, with the personal departure screen below. It is a working-paper method, not a certificate of treaty entitlement. Domestic rules come first; a ratified treaty and its current protocol/MLI require their own analysis. Published residence, nonresident-return and treaty-application forms are mapped below; no bilateral treaty rate or taxpayer's entitlement is established by their existence. Code 2/19(7)

Resident organisations are those located in Armenia, with organisation location defined by state registration; do not replace this statutory test with an invented universal place-of-effective-management rule. Resident profit taxpayers bring Armenian and foreign income into the tax base; nonresident corporate profit taxpayers are taxed on Armenian-source income, with separate PE and no-PE bases. Individual entrepreneurs, investment funds and other special regimes require their own classification rather than automatic application of the ordinary corporate rate. 22–23, 103–105, 125

For individual residence screening, Article 25 has the 183-or-more-days test, counting both arrival and departure days, and independent vital-interests/state-service limbs. If resident on a day under the stated limbs, the Code treats the person as resident for the entire tax year. Fewer than 183 days alone does not prove nonresidence. This is screening only: personal income categories, payroll, pension/social obligations and treaty dual-residence allocation are not computed by the corporate withholding table below. 25

Establish the PE and registration position

Article 27(1) lists places of business including production, management, extraction, construction, branch/representative operations and specified joint activity. Several listed activities do not have a universal 183-day grace period. The separate services/work limb in paragraph 2 uses at least 183 calendar days in a tax year and related-project rules. Exhibition/fair goods sales have a separate more-than-30-day rule. Preparatory/support relief has its own conditions, direct-beneficiary requirement and less-than-three-year period. Dependent agents and joint activity need distinct tests. 27(1)–(5), (9)–(10)

Paragraphs 7–8 distinguish activity characteristics, tax registration and the statutory calculation/payment consequence of an unregistered PE-like operation. No registration does not prove no PE risk. Conversely, do not claim that registration alone resolves treaty attribution. Retain contracts, actual conduct, staff/project days, premises, authority, registration date and income documents. The former paragraph 6 labour-supply rule was repealed by HO-377-N, effective after its December 2025 publication; do not use an older English consolidation to claim a blanket labour-supply PE exception in 2026. 27; HO-377-N Articles 1, 7

Rates, bands and thresholds

Ordinary domestic rules before separately established treaty/Code relief:

Population/receipt	Rate or test	Tax year and primary source
Ordinary resident corporate profit / attributable PE profit	18% on established taxable profit	2026, 125(1)
No-PE insurance indemnities, reinsurance fees and freight	5%	2026, 125(4)(1)
No-PE passive income, subject to specific exceptions	10%	2026, 125(4)(2)
No-PE dividends	5%	2026, 125(4)(3.1)
Specified securities capital appreciation / stated participation exception	Statute distinguishes 0% securities appreciation and 18% appreciation on the stated stocks/shares/units in another organisation	2026, 125(4)(4); actual instrument classification required
Other Armenian-source no-PE income outside the preceding categories	20%	2026, 125(4)(5)
Relevant listed-jurisdiction goods advance without outcome	Statutory deemed-income event on day 366 after payment where the 365-day condition is met	2026, 125(6); list/status/outcome must be established

Do not apply corporate interest/royalty withholding rates to an individual. Do not claim all securities are exempt or every participation gain is taxed on gross proceeds. Treaty relief, exempt-income provisions, beneficial receipt, instrument and recipient status must be resolved for the particular transaction. The examples assume no relief and ordinary established corporate scope. 103–105, 107–108, 125

Future gate: HO-385-N amends bank-dividend treatment, related distribution wording and reporting/payment provisions. Article 14 generally starts those amendments on 1 February 2027, with a separate expense provision effective earlier. It also reaches dividends distributed/paid from earlier-period profits. Neither July enactment nor an earlier profit year makes the future 15% bank-dividend rate current for an October 2026 event. Recheck the complete transition and later implementing instruments for 2027. HO-385-N Articles 2, 4–7, 14

The base

Classify the source before the rate

Article 107 determines source under the profit-tax rules, separately from VAT place of supply. Goods, actual work/services, intermediary activities, property, transport/post, telecoms, audit and passive receipts have different connecting factors. Interest/royalty and dividend payer connections are not interchangeable with the place where a supplier's staff sit. Armenian real-property rent is expressly sourced by property location. Inseparable work/service income can be fully Armenian-source under the stated rule, rather than apportioned by an arbitrary percentage. 107

Offshore consultancy, legal, accounting, management, expert, marketing, advertising, translation, engineering and similar services can be Armenian-source under paragraph 4. From 1 July 2026, HO-234-N Article 20 broadens that paragraph's recipient language to a resident organisation, Armenia-registered individual entrepreneur or the stated nonresident PE. Do not use the older English phrase limited to a resident profit taxpayer to omit a payment merely because the Armenian recipient uses a special regime. An unrelated offshore supplier is not automatically exempt. Actual treaty business-profits/PE and domestic relief remain separate, unverified questions here. 107(4); HO-234-N Articles 20, 33

Nonresident capital appreciation has document-specific initial/book/revalued-value rules in Article 107(3)(5); absent the specified evidence, the statute can treat the entire alienation value as appreciation. No reconstructed acquisition cost without documents. Full asset/security/immovable-property, related-party and treaty methods remain open, so no property-gain return is certified here. 107(3)(5), 125(4)(4)

Separate attributable PE profit from other receipts

For an ordinary registered corporate PE, Article 105(1)(3) uses taxable profit with applicable deductions, and Article 133 requires separated accounting and settlement-document identification of the PE for deductible expense. A head-office charge is not deductible just because a group spreadsheet allocates it. Pricing, actual benefit and current deduction restrictions require further evidence. 105, 110, 133; companion TP method

Article 125(1)/(5) ties attribution to the PE's supporting income documents, regardless of merely naming/not naming the PE as receiver in a contract. Non-attributed receipts have a separate gross-income/rate route. Article 132(4) separately addresses nonresident dividends regardless of attribution. Keep a receipt-by-receipt attribution register, then reconcile any tax-agent withholding credits under Article 130 rather than taxing the same receipt twice. The example below assumes the attribution and allowable costs already established; it does not verify every deduction. 105, 125, 130, 132–133

Payment events and gross/net agreement

Article 132 withholding operates on payment events, including part payments, property, set-off, restructuring/novation, specified claim assignment/waiver and the Article 109(3)(5) dividend-distribution decision. Cash leaving a bank is not the only trigger. From July 2026, HO-234-N Article 27 changes claim-assignment wording and clarifies the waiver event; use current Armenian text. Returned payments have paragraph-3 timing/corrected-report conditions, not automatic erasure of a filed liability. 109, 132; HO-234-N 27, 33

For a contract whose taxable amount is established as gross, withholding = gross × applicable rate and net = gross − withholding. If the agreement instead guarantees the recipient a net amount and the payer bears tax, first establish its legal/contractual character and tax base; under the examples' single-rate assumptions gross = net / (1 − rate). This is algebra under an assumed taxable gross base, not a statutory election or proof all payer-borne taxes are deductible. 105, 125, 132

Resident foreign-tax relief

Article 20 includes foreign taxable objects and permits reduction for corresponding taxes collected abroad under foreign law, capped at Armenian tax on those foreign objects calculated under the Code. Separate the foreign income/deduction/base reconciliation, comparable tax and collection evidence, currency/period and any treaty restriction. Do not credit VAT, penalties or an unsupported foreign assessment as corporate profit tax. Actual tax equivalence and multi-country/category allocation need the underlying instruments. 20, 130(1)(2)

Two limits are different. First calculate the Article 20(3) foreign-object cap; foreign tax above that cap is not automatically eligible carryforward. Then compare the legally deductible amount with the year's corresponding tax liability. Article 20(4) carries the deductible amount exceeding that annual liability into subsequent reporting years of the same tax type. Do not label all excess foreign tax refundable or carryable. Use the corporate Guide's signed 93–98 mapping and statutory eligible-use/carry workpaper; its printed field 95 formula defect must not consume credit above the annual liability. Competing relief, foreign adjustments and actual electronic acceptance require the stated separate evidence. 20(2)–(4), 130–131

Deadlines and filing

Obligation	Statutory date/clock	Source
Tax agent's nonresident-income return	By the 20th inclusive of the month following the reporting quarter	134(2)
Tax agent's nonresident withholding payment	By the 20th inclusive of the month following the payment quarter	136(2)
Ordinary resident/PE annual profit-tax return and payment	By 20 April inclusive of the following tax year	134(1), 136(1)
No-PE nonresident without a tax agent	Annual return by 20 April following the reporting year; statutory filing unit is the authority serving Yerevan Kentron district; relevant tax payment by that date	134(3), 136(3)

Keep the underlying payment event, income attribution, reporting quarter and annual period separate. These are statutory dates before a separately established extension/calendar adjustment. Do not turn a quarterly return into a monthly rule or defer withholding calculation to the return date. Use the corporate Guide's Article 135 method for PE instalments and its distinction between calculated advances and cash paid. 132/134–136

Quarterly tax-agent return: 326-N, current 1606-N version

Use the actual 326-N consolidation from 1 January 2025, amended by 1606-N. Header 1–4 identifies agent TIN/name/address and year/quarter. The new form records each nonresident's name, foreign taxpayer identifier, legal form where present, address, prescribed registration-country code and payment date, then income code/amount, rate and tax. Amounts are AMD without luma. Reconcile all payment events, including noncash events under 132, with the original-period ledger. 326-N form and instructions 1–23; 1606-N 1–2

Section	Population and reporting
1	Armenian-source income under domestic tax; columns 7–10 are income code, amount, applicable 125(4) rate and tax
2	Armenian-source income exempt or taxed at a reduced rate under an established effective treaty; retain the relief evidence, rather than deleting the payment from reporting
3	Armenian-source income paid to an Armenian PE; identify the PE and preserve attribution/withholding evidence separately
4	Specified non-Armenian-source income under 107(6); instruction 23 expressly excludes 108(2)(1) external-economic-activity receipts from this section

Quarterly instruction 12 distinguishes 001 dividend, 002 debt-obligation income including loan interest, 003 royalty other than the specified intellectual-property-use/right limb, 004 that intellectual-property-use/right income, 005 rent, 006 movable-property proceeds, 007 immovable-property proceeds, 008 securities proceeds, 009 insurance, 010 reinsurance, 011 freight, 012 other interest, 013 asset appreciation and 099 other Armenian-source income. This is a form-code list, not proof of source, taxable base or exemption. Do not copy the annual form's 006 royalty code into this quarterly return. Country codes come from instruction 10, not ISO assumptions. 326-N instructions 10–23

Future form gate: actual 995-N, 23 September 2026, replaces the order from 1 January 2027. Its special bank-dividend branch applies from 1 February 2027, including distributions from earlier-period results. It is not an October 2026 replacement. 995-N 1–3

Annual no-agent and PE return routes

Current 749-N Annex 4 is the actual no-PE/non-agent annual return under 134(3). Fields 1–4 are TIN if any, full name, location and reporting year. Fields 5–10 record ordinary taxable receipts by code and corresponding 125(4) tax; 11–16 separately record treaty-reduced taxable receipts/tax; 17 totals tax 10+16. Instruction 1 excludes 108 nonincome and fully treaty-exempt receipts from this form. Do not import that omission into the quarterly agent form, whose section 2 includes exempt treaty payments. The annual form uses 001 insurance, 002 reinsurance, 003 freight, 004 dividend, 005 interest, 006 royalty, 007 rent, 008 appreciation, 009 securities appreciation, 010 specified Pan-Armenian Bank dividend, 099 other. A printed historic label does not create a current rate or relief. 749-N Annex 4 form/instructions 1–15; 134(3)/136(3)

Registered PEs use 749-N Annex 1: section 1 contains only attributable income/deductions; section 2 contains non-attributed income received from non-agents. Section 2 ordinary tax is field 6, treaty-reduced tax field 12, total field 13; this feeds section 1 field 99. PE-attributable withholding credit belongs in section 1 field 97 only for the corresponding income included in that section's 6–40 rows; it is not a resident foreign-tax credit. Field 98 reconciles attributable tax after the eligible withholding credit; 100 adds 99. Then reconcile calculated advances 101 and the actual payment/account record. Final agent withholding on non-attributed receipts is not a second non-agent annual liability. 130(3)–(5)/134(1); 749-N Annex 1 instructions 1/26–37

Ordinary tax returns follow electronic filing 53(5), with its stated exceptions. Keep 53(7)'s system receipt/registration acknowledgment as filing evidence; a locally completed spreadsheet is not a return. Corrections under 54 retain the original period and are subject to 53(10)–(12), including the distinct liability-increasing route. Account settlement follows 325: pension obligations have priority, then the statutory oldest-due liability order; a payment into the unified account is not itself tax revenue until allocated to discharge a liability. Do not assume a bank debit settled this particular nonresident tax. 53–54/325

Armenian residence evidence

Current Article 314 provides electronic applications/certification, including qualifying foreign-country forms, separate years/countries and Armenian certificates with English/Russian on request. It distinguishes the organisation/registered-entrepreneur route from other individuals, including the latter's vital-interests evidence, and category-specific immediate/two-working-day processing provisions. Those legal clocks do not establish that a particular incomplete application was accepted. 314; HO-377-N 6–7

Actual 345-N as revised by 1629-N has Form 1 for organisations/individual entrepreneurs, Form 2 for individuals and Form 3 certificate. Reconcile TIN/legal name, tax year, destination country, identity/status grounds, supporting explanation and any foreign form. Certificate QR/control code, tax year and country must match the intended use. An Armenian certificate supports Armenian residence evidence; it is not a foreign recipient's certificate or blanket treaty relief. The SRC foreign-citizen service page describes that specific application route; do not apply it as every corporate process. No login, submission or issued certificate was obtained here. 314; 345-N forms; SRC service

Penalties and interest

Article 401 ordinary tax late-payment interest is 0.075% per overdue day, within its scope and 730-day maximum. Article 402 provides a late-return fine based on 5% of the relevant calculated tax for each completed 15-day period, subject to its calculation stop and total-tax cap. Article 403 provides ordinary under-declaration sanctions of 50%, or 100% for its specified recurrence, with express exceptions. Do not stack these automatically or reuse transfer-pricing documentation sanctions as nonresident-return fines. Establish the exact offence, tax-agent liability, original due date, service, correction and applicable exceptions. 401–403

The former PE staff-supply treatment, missing noncash withholding events and unjustified treaty relief are material classification risks. Full administrative-offence rules, amended-return relief, audit limitation, service/appeal/suspension deadlines, refunds and enforcement are not cleared by these numeric summaries. Do not invent an appeal period. 27, 54, 132, 401–403

Cross-border points

Before a treaty conclusion obtain the actual treaty/protocol, operative year, covered taxes/persons, residence/tie-breaker, payment article, PE/business-profits interaction and applicable anti-abuse/MLI provisions. Article 19(7) delegates the procedure to Government. No treaty count, residence certificate alone or generic model establishes exemption. 2/19/20/27

Published treaty applications: original order and actual amendment

ARLIS currently records 18 May 1998 order 01/29 and its 31 August 1999 amendment 01/13 as active. They are distinct from repealed Government 1398-N. The base order's old separate Armenian/English-copy requirement was changed: 01/13 allows Armenian, Russian or English and replaces the forms/appendices. Read both acts; the base /latest text does not silently incorporate this amendment. Do not revive 1398-N or describe its 613-N repealer as a replacement. The current Code 304 service and SRC specimen below supply the ordinary claimant/approval/account mapping; Code 447(8) supplies the conditional continuation rule. Current statutory requirements prevail over old office names and labels. 01/29 metadata and both procedures; 01/13 paragraphs 1–3/forms

Published procedure	Applicant/evidence, filing and decision
Relief before payment	Nonresident recipient or documented authorised representative completes four copies, in one of the amended permitted languages. SectionsI–II identify recipient/payer, identity/incorporation/address and payer TIN; III identifies income/contract, gross, domestic tax and proposed treaty rate/tax; IV certifies/request relief. The foreign competent tax/finance authority confirms treaty residence inV, retaining one copy. The remainingthree go to the Armenian office where the agent is registered. Its decision is recorded in VI; one copy remains there, two return to applicant, who retains one and gives the other to the agent as the specified basis for reduced/exempt withholding.
Refund after withholding	Recipient completes three copies, with the income/payment date, gross, actual withheld rate/tax, proposed treaty tax and difference, plus bank/location/account details. Foreign competent authority confirms treaty residence for the income period inV and retains one. Remainingtwo go to the payer's registered Armenian office; one remains and the approved copy returns to the applicant after VI decision. The difference is refunded under the general domestic procedure; this order does not supply an automatic refund deadline.

Sources: 01/29 relief instructions 1–9/refund 1–9, as amended by 01/13. The historical offices and form-year labels are preserved as published, not represented as a tested 2026 portal/modern office direction. Proposed treaty amounts require the actual applicable treaty; none is invented here. A foreign recipient's certified application differs from the separate 314/345-N Armenian residence certificate. Use the current SRC service/specimen below for the claimant and approval/account mapping; the actual treaty/MLI entitlement still requires the applicable instruments and taxpayer facts.

Current SRC refund specimen and the statutory service

Current Tax Code 304(2)(12) expressly assigns the tax authority the receipt and approval of the certificate application to refund tax collected from Armenian-source income. The SRC currently publishes the trilingual specimen certificate application on its dedicated refund page. The following mapping comes from that actual DOCX, rendered and read across three pages; its label is “specimen”, not proof of a new Government enactment. Read it with the applicable treaty and current statutory procedure, rather than treating a payer's own unified-account claim as an assignment to the foreign recipient. 304(1), (2)(8)/(12); SRC current service; actual current specimen, sections 1–6

Actual current specimen	Applicant, evidence and authority control
Section 1, page 1	Identify the income recipient by full name/entity name, identity/incorporation number/date and residence/business address. The recipient is distinct from the Armenian income payer.
Section 2, page 1	Identify the income payer and its TIN, identity/incorporation and address. Reconcile its withholding return and paid-tax evidence to the claimed income.
Section 3, pages 1–2	For each income item give supporting-document number/date, income type, payment date, gross income, currency, actual withheld tax in AMD, treaty tax in AMD and requested difference; reconcile the totals. The treaty amount requires the actual operative treaty/article and entitlement evidence.
Section 4, page 2	Give the receiving bank's name, location/address/contact and bank account, then sign/date the declaration of correct information. Match recipient/account evidence; this field is not blanket permission to select an unrelated third party's account.
Section 5, pages 2–3	The foreign competent authority certifies the applicant's treaty residence for the period when the income arose, with country, date/place, signature and seal. A company registration extract alone is not this certification.
Section 6, page 3	The Armenian tax authority records the amount approved for return from the budget, in AMD figures/words, with competent subdivision, head/signature/seal and date. An unsigned applicant calculation is not that approval.

Submit the certified recipient application and payer/income/withholding evidence to SRC using the applicable receipt/approval service; preserve its submission acknowledgment, approved amount and account instruction, and reconcile the eventual bank receipt to that approval. The historical 01/29 as amended procedure above routes through the payer's registration office; the current specimen itself does not set a new digital channel, a copy-count replacement or a guaranteed cash-transfer clock. Do not promise Code 327's 20/10-day clock merely because this specimen has been filed: that rule separately requires amounts available in the relevant unified account and its own statutory application. Do not substitute the unrelated agent's credit or an 864-N alternative-account exception without their actual legal conditions. 304, 327; 01/29 refund instructions; current SRC specimen

Code 447(8) conditionally continues pre-Code tax-benefit application frameworks until the corresponding Code instruments define a replacement. Code 19(7) retains the Government delegation. The active registry entries and SRC's current specimen support the documented application/approval path; they do not prove that a particular treaty/MLI claim is entitled to relief or identify every internal Treasury posting step. Any inconsistent current SRC direction or operative replacement must be reconciled before filing; a failed search is not evidence that no replacement exists. This is the documented current application, approval and account-instruction route. No newly identified Government enactment, unconditional bank-settlement deadline or complete internal Treasury posting workflow is asserted. 19(7), 304, 447(8); current SRC refund page

Personal source, property and no-agent filing

Build a person-by-year and receipt-by-receipt workpaper. Domestic residence under 25 is separate from citizenship, permission to reside and a treaty tie-breaker. Resident personal income includes Armenian and foreign receipts under 141(1)(1); an established nonresident's personal scope is Armenian-source income, with 141(1)(2)'s PE-attribution and defined external-economic-activity exclusions. Registered business profit remains separate from personal PIT. 25, 140–144

Receipt	Domestic source test before rate/exemption
Salary/equivalents and civil-contract income	144(1)(1)–(2) tests the contract with a resident taxpayer or a nonresident profit-taxpayer operating through an Armenian PE. Do not use physical workdays alone instead of that statutory contract test.
Nonresident employer's hired staff in Armenia	144(1)(5) separately covers Armenian work/services where the wage is an Armenian registered PE's expense, regardless of deductibility, and/or the staff are engaged in that PE's activity. Keep the actual duties, place, PE and expense evidence.
Passive income	Apply 144(1)(3)'s reference to 107(3): resident-company participation for dividends; the specified resident organisation/PE/Armenian-citizen payer for interest and royalties; Armenian immovable-property or the stated movable-property connection for rent; and the applicable Armenian asset/right connection for alienation. The corporate appreciation computation printed in 107 does not replace the individual's 143/147/150 base and rate.
Other income	Apply 144(1)(4)'s 107(5) payer/source connection and 144(2)'s rule treating otherwise unassignable other income as wholly Armenian-source. Income outside the preceding domestic-source provisions is foreign-source under 144(3). Do not automatically import the corporate offshore-service list in 107(4) into personal income.

144, 107(3)/(5). Preserve contract, title, payer status, place/source facts, actual 142 income event and foreign evidence. A foreign bank account is not proof of foreign source, and an Armenian bank receipt is not proof of Armenian-source taxable profit.

For an ordinary personally owned apartment/property sale, identify title, seller's personal versus entrepreneurial/developer status, buyer's status, source and receipt date first. Under 147(1)(16), proceeds received from a natural-person buyer who is neither entrepreneur nor notary are exempt, except the specified developer-premises and crypto-asset branches. A company buyer does not meet that private-buyer exemption. For an otherwise taxable ordinary personal property disposal, 150(9) charges 10% of total income, not 10% of net appreciation after cost. The developer branch has its own 145 base and 150(11) rate; it is not this ordinary branch. Land-alienation income has the separate exemption in 147(1)(38) regardless of designated land purpose; separate the actual land component from a building rather than describing every real-estate sale as land. 141–145, 147(1)(16)/(38), 150(9)/(11)

Keep exemption and declaration omission separate: the universal resident-citizen declarant's private-property sale follows the individual Guide's actual family/225-N receipt threshold rules. If the receipt is taxable, establish the payer's tax-agent duty under 152–153. Calculate tax only once, reconcile actual withholding/settlement, and use the agent or individual's actual reporting population. Personal rent uses 150(7)'s basic 10% and separate annual rent-excess test; do not apply the corporate nonresident rate table to an individual. 150–153, 156; individual declaration method

No agent does not always mean annual filing. Code 151(2) uses a monthly period for salary/equivalents and civil-contract work/services where an Armenian-ratified treaty releases the payer from tax-agent duties. That individual files the 300-N Annex 2 simplified return and pays by the 20th of the next month, under 156(4)(1)/158(2)(1). Establish that precise payer exemption before using it. A foreign employer by itself does not prove the 151(2) treaty branch. 151–154, 156(4), 158; 300-N Annex 2

Other personal self-assessed income in 151(3) uses the annual period. Under 156(4)(2), file the 300-N Annex 3 annual return from 2 March through 1 July of the following year, moving the opening day as the statute states; pay the independently calculated annual tax by 1 July under 158(2)(2). Separately, 156(4.1)'s universal declaration covers adult Armenian-resident Armenian citizens as at 31 December. Do not treat that citizenship/status gate as removing an otherwise applicable 156(4) obligation for a foreign citizen or nonresident. The special 2025-income November-2026 transition must be tested against its actual statutory population, not extended to every no-agent foreign filer. 151(3), 154, 156(4)/(4.1), 158; 300-N Annex 3; HO-76-N 5(2)

Reconcile category totals, non-taxable but reportable amounts, agent withholding, separate monthly self-assessments, foreign tax and available credit in their proper form fields. Use 20's corresponding-foreign-tax object cap and separate annual-liability/carry test, supported by the foreign-authority evidence required by 300-N; do not deduct foreign social insurance as foreign PIT or count a monthly liability again as unpaid annual tax. The companion individual Guide maps the actual published annual form and signed-refund condition. No live prefill or filing receipt was obtained. 20, 53–54, 143, 150–158; 300-N Annexes 2–3

Departure: re-test residence each year from actual travel days and retained vital interests. Code 25(5)'s whole-year rule means a flight does not itself end that year's worldwide-income treatment. In a later established nonresident year, classify continuing Armenian salary, rent, dividends, royalties and property receipts through the source/rate/exemption and agent/no-agent sequence above. Retain bank/portal access, authority notices, the relevant calendar and evidence of paid tax so that next-year filing and refunds are actually followed through. No unsupported special pre-departure deadline or automatic tax clearance is imposed here. A treaty override still requires the actual treaty and operative relief procedure identified separately below. 20, 25, 141, 144, 150–158

Two worked examples that recompute

All amounts are hypothetical AMD. Corporate recipient/scope, source, no relief and the stated dates/classification are assumed established. Examples are workpapers, not accepted filings.

1. Ordinary no-PE corporate royalty

October 2026 Armenian tax agent pays an established gross royalty of 10 million to a foreign company without an attributable PE. No treaty/domestic relief. At the 10% passive-income rate, withholding is 1 million and recipient net 9 million. Report/payment follow the quarter; an individual royalty requires separate PIT analysis. 107(3), 125(4)(2), 132, 134, 136

name: Armenia corporate royalty gross withholding
inputs:
  gross_royalty: 10000000
steps:
  - withholding: gross_royalty * 0.10
  - recipient_net: gross_royalty - withholding
expected:
  withholding: 1000000
  recipient_net: 9000000

4. Foreign-object cap is not unlimited carryforward

Ordinary resident company: established foreign taxable profit 30 million and domestic taxable profit 20 million, no other relief/prepayment. At 18%, total Armenian tax 9 million and foreign-object cap 5.4 million. Corresponding foreign tax actually collected is 7 million: deductible credit 5.4 million, Armenian balance 3.6 million. The 1.6 million above the foreign-object cap is not an Article 20(4) carryforward merely because it was paid abroad. 20, 125(1), 130

name: Armenia foreign object tax credit limitation
inputs:
  foreign_taxable_profit: 30000000
  domestic_taxable_profit: 20000000
  corresponding_foreign_tax_collected: 7000000
steps:
  - total_armenian_tax: (foreign_taxable_profit + domestic_taxable_profit) * 0.18
  - foreign_object_cap: foreign_taxable_profit * 0.18
  - deductible_credit: min(corresponding_foreign_tax_collected, foreign_object_cap)
  - armenian_balance: total_armenian_tax - deductible_credit
  - foreign_tax_above_object_cap: corresponding_foreign_tax_collected - deductible_credit
expected:
  total_armenian_tax: 9000000
  deductible_credit: 5400000
  armenian_balance: 3600000
  foreign_tax_above_object_cap: 1600000

Ask the client first

• What are the payer and recipient's legal forms, domestic/treaty residence, tax regimes and relevant tax years?
• What work, premises, projects, staff days, dependent agents and tax registrations exist in Armenia?
• What is each payment's actual nature, place/source, contract gross/net term, noncash event and PE supporting document?
• What treaty, current residence evidence, relief application, beneficial-receipt and anti-abuse evidence exists?
• What foreign taxable objects, corresponding taxes collected, prior credits/losses and carryforward records reconcile to the accounts?
• Which returns, notices, assessments, payment dates and existing disputes affect the next action?

Handoff: residence/PE/source matrix; exact amendment/event dates; attributable/non-attributed ledger; base/rate/gross-net computations; foreign-object credit and separate annual-liability carry register; actual forms/acknowledgements/payment reconciliation; unresolved treaty/procedure evidence. The README identifies the supplied ordinary domains and remaining specialist/operational boundaries. Independent country review and accountant attestation are separate quality steps.

Sources

Read on 24 October 2026. Current Armenian Code targeted Articles 2, 19–27, 103–107, 109, 125, 130–136, 314 and 401–403; English translation used with current amendments, not as sole October authority. HO-234-N targeted Articles 20, 27 and commencement; HO-377-N PE/certificate provisions; HO-385-N dividend/commencement provisions; actual 345-N residence applications/certificate and Article 314 read. No issued certificate, taxpayer facts, accepted filing, actual bilateral/MLI relief or professional attestation obtained.

Primary source	URL	Read on
Current Armenian Code	https://www.arlis.am/hy/acts/215611/latest	2026-10-24
Official English translation, limited currency	https://www.arlis.am/en/acts/231892	2026-10-24
HO-234-N July 2026 changes	https://www.arlis.am/hy/acts/226008	2026-10-24
HO-377-N PE/certification changes	https://www.arlis.am/hy/acts/217374	2026-10-24
HO-385-N future dividend changes	https://www.arlis.am/hy/acts/228632	2026-10-24
SRC 345-N residence forms	https://www.arlis.am/hy/acts/217191	2026-10-24
SRC foreign-citizen certificate service	https://e-services.src.am/en/services/f811e3c1-d638-4e7d-966b-f10a36040678	2026-10-24

| Current native Code 19–20/25/53–54/130/134/136/140–143/149/156/158/325, targeted ordinary residence, returns, credits, correction and settlement | https://www.arlis.am/hy/acts/215611/latest |2026-10-26| | Current SRC refund service and actual trilingual specimen, all three rendered pages/sections 1–6; Code 304(2)(12) and 447(8) targeted integration | https://www.src.am/am/getMenusContents/2044 ; https://www.src.am/storage/menu_contents_2044/dz_harkeriveradardz_certdim_6a29039d5adfd.docx ; https://www.arlis.am/hy/acts/215611/latest | 2026-10-26 | | Order 01/29: actual native relief/refund forms and complete respective instructions 1–9; active metadata from 28 August 1998 | https://www.arlis.am/hy/acts/20456/latest |2026-10-26| | Actual 01/13 amendment paragraphs 1–3 and replacement forms/appendices, active metadata 18 October 1999 onward; language rule differs from unincorporated base text | https://www.arlis.am/hy/acts/20140/latest |2026-10-26| | Current 326-N: quarterly form, complete instructions 1–23, metadata and future 995-N note; actual 1606-N replacement form/instructions compared | https://www.arlis.am/hy/acts/201372/latest ; https://www.arlis.am/hy/acts/200736/latest |2026-10-26| | Actual 995-N paragraphs 1–3 only: general 1 January 2027/bank-dividend 1 February 2027 gates; future form not implemented as 2026 | https://www.arlis.am/hy/acts/231490/latest |2026-10-26| | Current 749-N: Annex 4 complete form/instructions 1–15; Annex 1 targeted instructions 1/24–37 and actual relevant PE/foreign-credit/settlement fields | https://www.arlis.am/hy/acts/226558/latest |2026-10-26| | Native Code, complete 144/151/152/154/158, targeted 25/107(3)/(5)/140–143/147(1)(13)/(16)/(38)/150/153/156; ordinary personal source, property and no-agent filing integration | https://www.arlis.am/hy/acts/215611/latest | 2026-10-26 |

Targeted commencement recheck, 25 October 2026: HO-234-N art. 33(1) is the general 1 July 2026 commencement and enumerated 1 January 2027 exception provision. Article 31 instead amends Tax Code 293(2); it is not the commencement authority. Other source read dates remain as recorded.

Not yet confirmed: a separate current unconditional treaty-refund cash-transfer clock and complete internal Treasury posting workflow; the actual taxpayer's treaty/MLI entitlement requires its own facts and operative instruments. The current Code 304/SRC specimen claimant, approval and account-instruction route is supplied above. The ordinary personal source/property, agent/no-agent filing and departure method is supplied above. Specialist treaty-rate tables, restructurings, exit/CFC, securities and social-security instruments remain separate scope. No live return/refund/certificate or named accountant attestation is claimed; independent source-review records are preserved in the country research.

Contributed by Michael Cutajar.