At a glance
- Law HO-234-N was adopted on 6 May 2026 and published on 3 June 2026. Its Article 2, which restates Tax Code Article 16, has been in force since 1 July 2026.
- For most transactions, the Central Bank of Armenia rate “published for that day” now means the average rate published on the preceding working day. The former reading was the rate published by 16:00 on the transaction date.
- Actual foreign-currency exchange transactions are the exception: they use the average rate published on the exchange date itself.
- Tax withheld by an Armenian tax agent converts at the payment date. Where there is no tax agent, income converts at the income-recognition date under the taxpayer’s accounting method, and foreign tax paid abroad follows the same date.
- HO-234-N also contains its own Article 16, amending the Tax Code rules on nonresident VAT payments. That provision takes effect on 1 January 2027 and is a different rule from the Tax Code Article 16 restatement.
Since 1 July 2026, an Armenian taxpayer converting a foreign-currency amount for tax purposes uses the Central Bank of Armenia average rate published on the working day before the date the Tax Code assigns to the transaction. Until then, practice read the same statutory phrase as the rate published by 16:00 on the transaction date, which forced anyone invoicing or paying in the afternoon to wait for a figure that had not yet been issued. The restated Article 16 also sets out, point by point, which date attaches to which kind of transaction, so the answer no longer depends on which document happens to be dated first.
What changed under restated Article 16
HO-234-N replaced the whole of Tax Code Article 16 with a two-part structure. Part 1 contains seven points, each fixing the date on which a foreign-currency amount is converted. Part 2 contains two points, which fix the rate applied on that date. Reading only one part gives the wrong answer, because the conversion date and the publication date of the applicable rate are now different days for most transactions.
The change reaches every calculation that starts in a foreign currency: the VAT base on an invoice priced in euros, the profit-tax deduction for a dollar supplier payment, personal income tax on foreign earnings, withholding on payments to nonresidents, and the credit claimed in Armenia for tax already paid abroad. Existing worked examples in accounting manuals, platform help pages and English translations of the Tax Code that still refer to a 16:00 rate are describing the pre-July position. Several widely circulated sources have yet to be updated.
Rule one: which date applies
Part 1 of the restated article assigns a conversion date by transaction type.
| Transaction | Conversion date |
|---|---|
| Import or export outside the Eurasian Economic Union (point 1, subpoint ա) | Date of the customs declaration |
| Trade within the EAEU (point 1, subpoint բ) | Date the goods cross the border; for goods carried by air post, the date of the calculation document |
| Supply of goods or services (point 2) | The moment of supply fixed by Tax Code Articles 38 and 40, not the invoice date |
| Income taxed through an Armenian tax agent (point 3) | Date of payment |
| Income received where there is no tax agent, including any foreign tax attaching to it (point 4) | Date the income is recognised under the taxpayer’s accounting method |
| Foreign-currency exchange transactions (point 5) | Date of the exchange |
| Initial recognition of a receivable or a payable (point 6) | Date the debt arises |
| Everything else (point 7) | Date of recognition in accounting |
Point 4 applies whenever no tax agent is involved. Foreign-sourced income is the common case, but the trigger is the absence of a withholding agent, so Armenian-sourced income a taxpayer must self-declare falls under the same date rule. Foreign tax paid abroad is drawn into that point as well, which keeps the credited amount and the underlying income on a single conversion date.
Rule two: which rate applies
Part 2, point 1 sets the general rule: the Central Bank average exchange rate published on the working day preceding the date identified above. Weekends and public holidays move the reference backwards, so a transaction dated Monday 3 August 2026 takes the rate published on Friday 31 July 2026, and a transaction on the day after a public holiday takes the rate published on the last working day before that holiday.
Part 2, point 2 carves out actual foreign-currency exchange transactions, the point 5 category. When currency is genuinely bought or sold, the rate is the average rate published on the exchange date itself. Converting a euro invoice into drams for VAT purposes is a valuation exercise and stays on the preceding-day rate; selling those euros to a bank is an exchange and takes the same-day rate. The practical effect is that a company can be using two different Central Bank rates in the same week for the same currency, and the difference between them lands in the accounting record as an exchange gain or loss.
Who this affects
Armenian companies and individual entrepreneurs invoicing in foreign currency. Point 2 governs the VAT base and the revenue figure; point 6 governs the receivable recorded against it. Both run off the preceding-working-day rate, so a company that registered through Armenian business registration and prices its work in dollars should be pulling the rate a day earlier than its 2025 templates did.
Foreign tax residents and remote workers declaring foreign income. Individuals generally recognise income on receipt, so point 4 ties the conversion to the day the money arrives and Part 2, point 1 supplies the rate from the day before. Anyone holding a digital nomad visa or otherwise self-declaring foreign earnings should be reading bank credit dates, and the same date carries the foreign tax withheld at source into the Armenian credit computation.
Withholding agents paying nonresidents. Point 3 fixes the payment date, which for most Armenian payers means the value date on the outgoing transfer. Employers running payroll for foreign staff under Armenian work permits apply the same mechanic to any element of remuneration denominated in a foreign currency.
Importers and exporters. Point 1 splits by trade route. Goods cleared through customs outside the EAEU convert at the declaration date; goods moving within the EAEU convert at the border-crossing date, with air post referred to the calculation document. Businesses moving money for these settlements should read the exchange itself as a separate point 5 event with its own rate, a distinction that also matters for how Armenian bank accounts record conversion gains and losses.
Four worked examples
The rates below are illustrative and rounded to AMD 395 to USD 1 for readability. Use the published Central Bank figure for the day the rule points to.
1. Payment to a nonresident consultant. An Armenian company pays USD 10,000 to a nonresident consultant with value date Wednesday 5 August 2026. Point 3 sets the conversion date at 5 August. Part 2, point 1 sends you to the average rate published on Tuesday 4 August. At an illustrative AMD 395, the base for the withholding calculation is AMD 3,950,000 (about USD 10,000).
2. Services invoiced in euros. An Armenian IT company completes a delivery on Friday 14 August 2026 and issues its invoice the following Monday. Point 2 fixes the conversion at the moment of supply under Articles 38 and 40, which is 14 August. The rate is the one published on Thursday 13 August. The invoice date changes nothing.
3. Selling dollars to the bank. The same company sells USD 50,000 (about AMD 19,750,000) from its account on Thursday 20 August 2026. This is a point 5 exchange transaction, so Part 2, point 2 applies and the rate is the average rate published on 20 August itself.
4. Foreign income with tax withheld abroad. An Armenian tax resident on a cash basis receives USD 4,000 (about AMD 1,580,000) from a foreign client on Monday 3 August 2026, from which USD 400 (about AMD 158,000) was withheld at source. Point 4 sets the recognition date at 3 August for both the income and the foreign tax. Part 2, point 1 supplies the rate published on Friday 31 July, and that single rate governs the declared income and the credit claimed against it.
Two Article 16s, two effective dates
HO-234-N is an omnibus amending law, and it has an Article 16 of its own. That provision amends the Tax Code rules on nonresident VAT payments and takes effect on 1 January 2027. The currency-conversion restatement discussed here is Article 2 of HO-234-N, operative since 1 July 2026. Commentary that reports “Article 16 is deferred to 2027” is describing the nonresident VAT amendment, and applying that deferral to the conversion rules would leave a taxpayer using a rule that was superseded on 1 July 2026.
No State Revenue Committee order or methodological instruction implementing the restated article has been located. HO-234-N Article 33(7) does not require one, which supports treating the statutory text as directly operable. No reported Cassation Court or Constitutional Court decision construing the restated conversion rules has yet been identified.
One drafting question remains open for 2027. Law HO-83-N, operative from 1 January 2027, restates a subpoint of the former Article 16 that the current text no longer contains. How the two are reconciled has not been clarified, so the position for transactions from January 2027 should be rechecked before it is relied on.
Frequently asked questions
Which rate applies to a July 2026 invoice?
Does this change the VAT base?
What rate applies when I actually exchange currency at a bank?
What rate do I use for a Monday transaction?
Is the nonresident VAT change in force yet?
Has the State Revenue Committee issued implementing guidance?
Does this affect my foreign tax credit?
Has any Armenian court interpreted the new wording?
What to check in your own records
Four checks catch most of the exposure created between 1 July 2026 and today. Re-run any foreign-currency VAT calculation dated on or after 1 July that used a same-day rate. Confirm that your accounting system pulls the Central Bank rate with a one-working-day offset and handles holidays. Separate exchange transactions from valuation entries so the same-day exception is applied only where it belongs. Check that self-declared foreign income and the foreign tax credited against it were converted on the same date, since splitting them produces a credit that does not match the income it relates to.
Wider context on Armenian tax obligations for residents and businesses is set out on our Armenian taxes page.
Last updated: August 11, 2026
