June 16, 2021
Armenian tax authorities begin transfer pricing audits
Armenian transfer pricing (TP) rules came into force in 2020. The TP rules introduced the notification on controlled transactions and documentation requirements with 2020 being the first reporting period. TP notifications for 2020 were due by 20 April 2021, and now the tax authorities have started requesting TP documentation in order to select taxpayers for TP audits. According to the Armenian Tax Code, TP documentation should be provided within 30 working days upon request of the tax authorities.
There is a separate division at the State Revenue Committee of Armenia responsible for implementation of the TP control, including TP audits, and international tax cooperation. In 2019, a Memorandum of Understanding on technical assistance to the Armenian tax administration was signed between Armenian and Italian tax authorities within the framework of the OECD1 and UNDP2 Tax Inspectors Without Borders initiative. Italy’s tax professionals are going to provide practical assistance to the Armenian tax authorities within the three key areas of cooperation: TP, criminal investigation and aggressive tax planning.
TP audit activity is expected to increase in Armenia as the tax authorities develop their capability. Armenian taxpayers should review their intercompany transactions on a regular basis and prepare contemporaneous TP documentation in order to justify their TP positions and to avoid disputes.
For additional information with respect to this Alert, please contact the following:
Ernst & Young CJSC, Tax & Law Services, Yerevan
Ernst & Young Kazakhstan LLP, International Tax and Transaction Services – Transfer Pricing, Almaty