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Armenia - Treaty Withholding Rates Table

This chart is based on information available up to 1 February 2015. Effective date: 1 January 2014.

The following chart contains the withholding tax rates that are applicable to dividend, interest and royalty payments by Armenian companies to non-residents under the tax treaties in force as at the date of review. Where, in a particular case, a treaty rate is higher than the domestic rate, the latter is applicable.

To obtain tax treaty benefits, a non-resident must provide the withholding agent with a certificate of residence issued by the state in which he resides. The withholding agent may then apply the reduced (or exempt) rate accordingly.

A special procedure applies for the refund of excess tax paid if treaty relief was not applied at source. The special permission of the State Tax Service is issued upon the taxpayer's request for a refund of the excess tax paid. The request must be filed in a standard form stating the taxpayer's residence and be certified by the competent authorities of the taxpayer's state of residence.

The maximum withholding rates allowed under Armenian tax treaties in force are as follows:

Armenia - Treaty Withholding Rates Table

1.

Most tax treaties provide for an exemption for certain types of interest,  e.g. interest paid to public bodies and institutions or in relation to sales on credit. These exemptions are not indicated in the table.

 2.

Unless stated otherwise, the reduced treaty rates given in this column generally apply if the recipient company holds directly or indirectly at least 25% of the capital or the voting power, as the case may be, of the company distributing dividends.

 3.

The rate applies if the recipient company holds at least 10% of the capital of the Armenian company.

 4.

The zero rate applies, inter alia, to interest paid to banks. Conditions may apply.

 5.

The rate applies if the recipient company holds at least 30% of the capital of the Armenian company.

 6.

The rate applies if the capital invested by the recipient company exceeds USD 100,000.

 7.

The lower rate applies to interest paid to a bank or financial institution.

 8.

The lower rate applies if the Canadian company owns directly at least 25% of the capital of the Armenian company and the capital invested exceeds USD 100,000.

 9.

The lower rate applies, inter alia, to interest from bank loans.

 10.

The rate applies if the capital invested by the recipient company exceeds EUR 150,000.

 11.

The lower rate applies to copyright royalties, including films, etc.

 12.

The higher rate applies to copyright royalties, including films, etc.

 13.

The zero rate applies if the recipient company has owned, directly or indirectly, at least 25% of the Armenian company's capital for at least 2 years. Conditions may apply. The 5% rate applies if the recipient company holds at least 10% of the capital of the Armenian company.

 14.

The 0% rate applies to interest paid to state or any institution wholly owned by the state. The 5% rate applies, inter alia, to interest paid to banks. The 10% rate applies in other cases.

 15.

The lower rate applies if the Italian company has owned directly at least 10% of the capital (totalling at least USD 100,000 or the equivalent in other currency) of the Armenian company paying the dividends for at least 12 months.

 16.

The zero rate applies to interest paid by a public body and to interest from bank loans.

 17.

The 5% rate applies if the Netherlands company owns directly at least 10% of the capital in the Armenian company; the 5% rate is reduced to zero if the profits out of which the dividends are paid have been effectively subject to the normal rate of corporate income tax in Armenia and the dividends are exempt from tax in the hands of the recipient company in the Netherlands.

 18.

The rate applies if the recipient company holds directly at least USD 40,000 of the capital of the Armenian company.

 19.

The rate applies if the recipient company has owned, directly or indirectly, at least 25% of the Armenian company's capital for at least 2 years.

 20.

The rate applies if the Swiss company holds directly at least 25% of the capital of the Armenian company and the capital invested exceeds CHF 200,000.

 21.

The 10% rate applies to interest paid to qualifying banking and financial institutions. The domestic rate applies in other cases (there is no reduction under the treaty).

 22.

The 15% rate applies, under conditions, to dividends paid out of income derived directly or indirectly from immovable property by certain investment vehicles.

 23.

The 5% rate applies if the UK company holds directly at least 25% of the capital of the Armenian company and the capital invested exceeds GBP 1,000,000. The zero rate applies if the beneficial owner of the dividends is a pension scheme.