Armenian government makes law-abiding taxpayer certificates indefinite
From January 1, 2027, Armenia’s tax compliance (law-abiding taxpayer) certificate will be issued indefinitely instead of for 12 months, and the tax authority will check every quarter whether holders still meet the criteria. At the same time, the requirements for obtaining a certificate are being tightened: new criteria are added, and investment funds will no longer be eligible.
The government adopted amendments to its 2021 decision No. 1324-N on October 8. According to the explanatory note, the aim is to make the law-abiding taxpayer system more attractive and to align the decision with the Tax Code amendments adopted on July 3, 2026 (Law HO-344-N). The draft was prepared by the State Revenue Committee (SRC).
The threshold for permitted violations is being raised. Additional liabilities assessed in audits must not exceed 0.1% of the value-added tax (VAT) base for the review period (previously 0.05%) and AMD 10 million (about $27,600), up from AMD 4 million. The criteria for timely filing and payment of taxes will be considered met if violations were recorded no more than twice.
Under the new criteria, a certificate will go to a VAT payer that has not posted a tax loss consecutively in the review period and the two preceding tax years, has paid at least 2 employees above the minimum wage in more than half of the months, and holds all licenses, permits and notifications required for its activity.
The list of violations is expanded: there must be no violations under Articles 407-409 of the Tax Code during the review period, while a breach of Articles 412, 416, 419 or 424 of the Tax Code or Article 165 of the Code of Administrative Offenses is allowed no more than once. Data on related taxpayers will also be assessed against these criteria.
The decision also sets the procedure for revoking a certificate. Monitoring will take place every quarter within 7 working days after the filing deadline and cover the period from January 1 of the previous year to the last day of monitoring. A certificate will be revoked if the taxpayer no longer meets any of the criteria, including if it has overdue liabilities, additional assessments exceed 0.1% or AMD 10 million, or a criminal case over economic crimes or smuggling has not been closed by the 1st of the second month after it was opened. The order of the SRC chairman revoking the certificate will be sent to the taxpayer electronically, and a new application may be filed from the 1st of the 12th month after the month of revocation. The list of taxpayers whose certificates were revoked will be published on the SRC website.
The certificate issued for inclusion in the register of Authorized Economic Operators will remain valid, as before, until the end of the 12th month following the month of issue. The new rules will apply to VAT-paying companies and sole proprietors that apply after January 1, 2027. According to the explanatory note, no significant changes in state budget revenues or expenditures are expected.
