Non-Resident and SaaS VAT Registration in Armenia: What Changes on 1 January 2027 (GD 1192-N)

A foreign company selling software, subscriptions or other digital services to consumers in Armenia owes Armenian VAT at 20% from its first sale, with no registration threshold, no local company and no Armenian bank account. That duty took effect on 1 January 2022. What arrives on 1 January 2027 is a wider version of it, delivered through three instruments that took effect together: Government Decision 1192-N, Law HO-234-N and Law HO-83-N.

What changes on 1 January 2027

Government Decision 1192-N was published on 13 August 2026 and takes effect on 1 January 2027. It amends Government Decision 184-N, the 2022 instrument that created the online registration procedure for foreign suppliers of electronic services. Two things happen. The procedure stops being reserved for B2C e-service suppliers and becomes available to every permanent-establishment-less non-resident directly liable under Article 70(2)(5). And every reference to petekamutner.am is replaced with src.am. Companion Decision 1189-N makes the same substitution in the payment procedure.

Law HO-234-N changes the underlying liability rule. Today, a non-resident is directly liable for VAT when its Armenian customer cannot act as a withholding tax agent, which in practice means individuals, microenterprises and turnover-tax payers. From 1 January 2027 the provision reaches supplies to any Armenian organisation that is not a VAT payer, subject to narrow carve-outs, and to individual entrepreneurs. A foreign supplier whose Armenian customers are all small businesses may therefore acquire a registration duty on 1 January 2027 without changing anything about its own operations.

Law HO-83-N addresses goods sold through marketplaces. It shifts the VAT obligation onto the EAEU e-commerce platform operator for third-party sales of goods to Armenian individuals, adds a new Article 76.1 with monthly reporting for that category, and adds a zero rate at Article 65(2)(14) for EAEU-bound exports made through platforms.

Published guidance from VAT-compliance vendors still describes the 2022 system as the current and complete picture. For a B2C SaaS supplier, that description survives 2027 intact: the rate, the threshold and the filing rhythm are unchanged. The 2027 instruments extend who is caught and where the filing happens.

Who has to register

The default rule sits in the opening paragraph of Article 70(2): where a non-resident without a permanent establishment supplies an Armenian VAT-registered customer, that customer accounts for the VAT as tax agent and the supplier registers nothing. Article 70(2)(5) covers the case where the customer cannot perform that function. An Armenian consumer cannot withhold, so the foreign supplier carries the obligation itself and must register.

Registration is mandatory once the conditions are met. The simplified portal route is the only lawful way for a permanent-establishment-less supplier to discharge the liability, which makes it a compliance requirement rather than an election. No turnover figure, transaction count or de minimis window applies at any point.

Two categories are captured from 2027. Foreign suppliers of electronic and cross-border services fall under Article 70(2)(5) as amended. EAEU marketplace and platform operators fall under HO-83-N and use the same portal, with the monthly Article 76.1 return applying to their platform sales of goods.

One point in the 2027 wording is unsettled. Whether a VAT-registered Armenian individual entrepreneur sits inside or outside the extended direct-liability rule is grammatically ambiguous on the face of HO-234-N, and the State Revenue Committee has published no clarification.

How the simplified registration works

The whole process runs online, in Armenian, English or Russian. There is no branch, representative office or Armenian bank account requirement, and no physical paperwork. The applicant answers a short set of qualifying questions, verifies an email address, completes the digital application and signs with a simplified electronic signature. The State Revenue Committee issues a tax identification number together with portal credentials, and published processing time for the 2022 route has been one business day.

The application asks for the entity name, country of residence, registered address, home-country registration number and date of registration, website, telephone number and contact details for an authorised representative. Decision 184-N does not oblige a foreign supplier to appoint a local Armenian tax representative; the form’s representative field is a contact requirement, and the position for the widened 2027 class has not been separately confirmed.

The move from petekamutner.am to src.am

Decision 1192-N strikes petekamutner.am from the registration procedure and substitutes src.am, effective 1 January 2027. Decision 1189-N does the same for the payment procedure. In practice src.am has been operating since the August 2026 publication, so existing registrants have a period in which both addresses are current in ordinary use while only one of them is written into the regulation.

Neither decision addresses credential migration, redirects, dual running or revalidation of existing tax identification numbers, and the State Revenue Committee has issued no operational notice on the changeover. Registrants who rely on saved logins or automated filing integrations should plan for the possibility of re-authentication in the fourth quarter of 2026.

Filing, payment and invoicing once registered

Registrants under Article 288(9.1) file quarterly, by the 20th day of the month following the end of the quarter. First-quarter VAT is therefore due by 20 April. The return form is the one prescribed by State Revenue Committee Order 47-N. The rate is the standard 20%, with no reduced band, flat-rate scheme or margin scheme available to this category.

Receipts in foreign currency are converted at the Central Bank of Armenia official rate on the last day of the reporting quarter. Payment does not have to be made in dram: Decision 406-N permits an international wire in foreign currency, with the intermediary bank converting so that the amount credited to the treasury account is in dram. Card payment is also supported.

Two compliance points have no settled source. The filing frequency for supplies to Armenian businesses that are not VAT payers reads as quarterly under Article 288(9.1), and Decision 184-N has not been formally amended to track the widened 2027 scope. And no ARLIS or State Revenue Committee source confirms whether registrants under this route are exempt from Armenia’s domestic XML e-invoicing system, which applies to resident businesses.

What non-registration costs

A supplier that should have registered and did not faces assessment of the unpaid 20% on its historical Armenian sales, plus the following:

• Late filing: 5% of the calculated tax for each completed 15-day period of delay, subject to the cap in Article 402.
• Understatement: 50% of the understated amount, rising to 100% for a repeat understatement within one year.
• Interest: 0.075% per day, approximately 27.4% a year, capped at 730 days.

Decision 1192-N contains no amnesty and no transitional relief for VAT accrued between 2022 and 2027. How far back an assessment can actually reach turns on the Tax Code’s assessment-limitation rules applied year by year, which is a case-specific analysis. Suppliers in that position should also read our note on the VAT registration cure window, which deals with a separate correction mechanism for historic exposure.

What to do before 1 January 2027

1. Segment your Armenian customer base into VAT-registered businesses, non-VAT-payer businesses and individuals. Only the first group leaves you outside the direct-liability rule from 2027.
2. Quantify sales to Armenian individuals since 1 January 2022. That is the historical base an assessment would work from.
3. Register through the portal and obtain a tax identification number before the first 2027 filing period opens, so the 20 April 2027 deadline is not the first contact with the system.
4. Marketplace operators: build the monthly Article 76.1 return into the reporting calendar, separately from the quarterly return for services.
5. Confirm portal access after the src.am substitution takes effect, particularly where filing is automated.

Related reading: Taxes in Armenia, VAT registration for foreign businesses, and VAT exemptions and deferrals in Armenia.

Frequently asked questions

Last updated: 27 August 2026