Armenia’s Tax-Compliance Certificate Becomes Indefinite From 2027 (GD 1449-N): Who Qualifies and What Can End It

Armenian VAT payers that apply for a law-abiding taxpayer certificate (the tax-compliance certificate) after 1 January 2027 will receive one with no expiry date. Law HO-344-N amends the Tax Code to that effect, and Government Decision 1449-N of 8 October 2026 sets new conditions for getting the certificate, a quarterly check on every holder, and 12 grounds on which the SRC ends it.

What changes on 1 January 2027

Until now the certificate ran from its date of issue to the last calendar day of the 12th month after the month of issue, and holders reapplied each year. Two acts change that:

• Law HO-344-N was adopted on 3 July 2026, signed and published on 17 July 2026, and enters into force on 1 January 2027. It amends the Tax Code so that the certificate is issued indefinitely, with the start of its validity stated on the certificate.
• Government Decision 1449-N was adopted, signed and officially published on 8 October 2026 and also enters into force on 1 January 2027. It amends GD 1324-N of 12 August 2021, the decision that sets the criteria and the issuing procedure. It applies to VAT-paying organisations and individual entrepreneurs that submit an application after 1 January 2027.

HO-344-N also makes four smaller changes. Investment funds can no longer obtain the certificate. A holder is assigned an individual service specialist by order of the head of the tax authority within one working day after issuance, with the specialist’s details emailed within one working day after the order. Holders get an additional coefficient of 0.8 in the risk criteria used to select companies for comprehensive tax audits, which lowers their audit-risk score; it gives no exemption from audit and no tax reduction. The SRC publishes a list of holders and a separate list of taxpayers whose certificates were terminated.

Neither act says whether a certificate issued before 1 January 2027 becomes indefinite, and neither sets a rule for an application still under review on that date.

Who qualifies under the 2027 rules

Every condition is measured over an observation period running from 1 January of the year before the application year to the last day of the month before the application. For an application made on 15 March 2027, that is 1 January 2026 to 28 February 2027: 14 months, so “more than half the months” means at least 8.

To qualify, the applicant must meet all of these conditions:

• be registered as a VAT payer on the application date and on every day of the observation period;
• have a positive VAT taxable base in more than half the months of the period;
• have no overdue tax obligations;
• have calculated monthly salary and salary-equivalent payments for at least two employees in more than half the months, with every calculated amount above the minimum monthly salary;
• hold, on the application date, every licence, patent and notification its activities require, and have no recorded infringement in the period for operating without one;
• have no consecutively arising tax loss across the observation period and the two preceding tax years, with results calculated without losses carried forward;
• have additional tax liabilities, assessed for infringements in the period, of no more than 0.1% of the VAT taxable base declared for the period and no more than AMD 10 million (about USD 27,700 at the house rate of AMD 361.36 per USD, CBA rate of 19 October 2026). Both limits apply. The previous limits were 0.05% and AMD 4 million (about USD 11,100 at the same rate).

Late filing of a tax calculation and late payment, including late advance payments, do not bar the certificate if they were recorded no more than twice in the period.

The SRC’s press explanation of 9 October 2026 describes two of these tests differently from the decision: it drops the word “consecutive” from the loss test and says licences must be held “during the observation period”. The decision’s own wording governs, and it is the wording used above.

How to apply

1. Submit the application electronically to the SRC on Form 1, choosing the ordinary certificate (Form 2) or the certificate for the AEO register (Form 3).
2. The SRC examines it within 15 working days. If a condition is not met, it sends a letter giving the discrepancies and the grounds for refusal.
3. You may object within 5 working days of receiving that letter. The SRC then issues the certificate or refuses it within a further 5 working days.
4. A Russian or English version of the certificate is available on request.
5. The SRC adds the holder to its published list within 2 working days after issuance.

GD 1449-N leaves this procedure as it was, apart from the choice between Forms 2 and 3 on the application.

Quarterly monitoring and what can end the certificate

A new Annex 3 to GD 1324-N governs holders. The SRC reviews each one every quarter, within 7 working days after the relevant return-filing deadline, looking back to 1 January of the year before the review. The certificate is terminated if the review finds any of these:

• the holder was not a VAT payer on every day of the period;
• no positive VAT taxable base in more than half the months;
• overdue tax obligations on the last monitoring date;
• a required tax calculation not submitted on time;
• a tax, including an advance payment, not paid on time;
• more than one infringement of the specified Tax Code reporting and record-keeping provisions, or of the related Administrative Offences Code provision;
• an infringement for operating without a required licence, patent or notification;
• additional liabilities above 0.1% of the VAT taxable base or AMD 10 million;
• specified economic-crime or smuggling proceedings that have not been terminated by the first day of the second month after they were opened;
• consecutive tax losses;
• failure of the two-employee minimum-salary test;
• late filing or late payment recorded more than twice.

The decision lists late filing and late payment as grounds in their own right and, separately, as a ground where they are recorded more than twice. It does not reconcile the two, and no official clarification has been published, so a holder cannot rely on two late filings being tolerated.

Where a holder has been reorganised, the review takes account of its predecessors. For the overdue-obligations and criminal-proceedings grounds, related taxpayers are also taken into account.

What happens on termination

The SRC draws up its conclusion within 2 working days. Termination is made by order of the head of the tax authority and takes effect the next day. The order is sent to the taxpayer electronically within 2 working days, and the taxpayer is added to the published list of terminated certificates within 2 working days.

A terminated holder may apply again from the first day of the 12th month after the month that included the termination day. A certificate terminated on 20 March 2027 allows a new application from 1 March 2028. The SRC rejects earlier applications.

The AEO exception: a certificate that still expires

A certificate issued on Form 3, solely for inclusion in the register of authorised economic operators, keeps a fixed term. It runs from its date of issue to the end of the last calendar day of the 12th month after the month of issue: a Form 3 certificate issued on 15 March 2027 is valid until 31 March 2028.

The Law on Customs Regulation (HO-353-N of 14 September 2022) makes this certificate a condition of entering the AEO register. A Form 3 applicant must also meet that law’s activity and volume conditions, must have no ground for refusal under the EAEU Customs Code, and must keep additional tax liabilities within a separate threshold of 0.8% of its VAT taxable base. That 0.8% threshold is unrelated to the 0.8 audit coefficient described above, and GD 1449-N does not replace it.

AEO status itself comes from a different document: the certificate of inclusion in the AEO register, granted by the SRC as customs authority.

Different from a tax residency certificate

The tax-compliance certificate attests that a VAT payer meets the SRC’s compliance criteria. A tax residency certificate confirms that a person or company is resident in Armenia for tax purposes, is issued for a particular year and a particular country, and is used to claim double-tax-treaty relief. The 2027 reform does not touch it. Our pages on the Armenian tax residency certificate, its benefits, the online platform for obtaining it and the 183-day residency test cover it.

A company planning to apply early in 2027 should check its payroll, licences, notifications and loss history against its own observation period now, since a failed test in any month of that period counts. Our Armenian tax practice and business registration team handle the related filings.

Frequently asked questions

Last updated: 23 October 2026