Armenia’s New Tax Debt Collection Rules: The 7-Day Window You Can’t Afford to Miss (HO-104-N)

Since 1 July 2026, an unpaid Armenian tax balance above AMD 200,000 (about USD 505) produces a State Revenue Committee reminder on the day the liability arises, and the taxpayer then has seven calendar days to file written objections before the SRC can order collection and freeze bank accounts. The mechanism sits in Article 398(5) of the Tax Code, introduced by law HO-104-N.

The seven days run from the day after the reminder is placed in the taxpayer’s electronic personal account, whether or not anyone opens it. For an Armenian company managed from abroad, that account is usually the only place the reminder ever appears.

How the SRC’s reminder-to-attachment process works

A tax liability arises on the day following the statutory payment deadline, if the tax is still unpaid on that day. Where the personal account card then shows arrears exceeding AMD 200,000, the SRC issues its reminder the same day. Where the arrears are AMD 200,000 or less, the reminder is issued once two months have passed from the day the liability arose. Liabilities assessed through a tax audit run on a separate track under Article 398(6).

Article 36.1 of the Tax Code, added by HO-104-N, fixes when an electronic notification takes legal effect: the day after it is placed in the taxpayer’s electronic account. That is the day the seven-day clock starts, and it is the reason the date shown on the reminder and the date the deadline runs from are rarely the same.

Once the window closes with no objections filed, or with objections rejected, the head of the SRC or an authorized official adopts a single decision that orders collection and attaches property in one act. The SRC may adopt it from the working day after the seven days expire. The decision reaches funds in bank accounts and registrable or accounted movable and immovable property, capped at the amount of the liability, under Articles 429(1), 430(2) and 431(1).

Debts that predate 1 July 2026

Article 10(2) of HO-104-N covers liabilities that arose and remained unpaid before the commencement date. For those, the SRC’s deadline for adopting the Article 398 decision is counted from the tenth day after the law came into force. The transitional rule moves that single deadline. Older arrears are inside the procedure, with a short administrative lead time before the first decisions could be issued.

The seven-day objection window and what it does not stop

The seven days are a right to be heard before the decision is taken, not the deadline for appealing it afterwards. Objections are submitted in writing through the electronic system, and they oblige the SRC to deal with the substance of the objection before it can proceed to collection. A taxpayer who files inside the window and disputes the balance on the merits changes what the SRC has to do next.

After the decision is adopted, the routes are an appeal to the SRC Appeals Commission or a claim in the Administrative Court. Article 432(5) of the Tax Code, replaced by HO-104-N, states that a judicial or extrajudicial appeal does not suspend execution of the decision. The bank freeze and the property attachment remain in place for the entire length of the challenge.

That rule drives the practical sequence for a company whose accounts are already frozen over a balance it believes is wrong. Payment is the only step that lifts the freeze while the dispute continues. Where the arrears come from a filing error on a dormant entity, the usual path is to clear the balance, restore banking, and then pursue reassessment or refund through the Appeals Commission or the court.

Why foreign-managed and dormant companies are the most exposed

The reminder is delivered electronically, into the personal account card at file-online.tax.am. Nothing is posted abroad. A director in Dubai or Los Angeles who has never logged in has no way of learning that seven days are running.

A non-resident director can obtain access without travelling to Armenia. According to SRC guidance published in April 2024, the sequence is a tax identification number first, then an electronic signature issued by EKENG CJSC. The request goes through e-request.am with identity documents, and where the applicant holds no Armenian public services number, EKENG issues the “CoSign with TIN” variant. The SRC then emails a registration link for the electronic services system.

Delegation is the more durable answer for anyone outside the country. Inside file-online.tax.am the taxpayer can authorize a local accountant or lawyer by tax identification number, so that someone in Armenia sees the account on a daily basis and the director’s own login is never the single point of failure. The alternative is a notarized power of attorney, apostilled or legalized for use in Armenia, presented in person to the SRC Taxpayer Service Department.

Dormant entities carry a particular risk under the two-month branch of the rule. An Armenian LLC that trades nothing still has filing obligations for as long as it stays on the register, and a missed return can leave a small balance sitting below the AMD 200,000 line. That balance produces no immediate reminder, matures quietly for two months, and then enters the same seven-day sequence as a large debt. Companies kept alive purely to hold an asset or preserve a name are the classic case. Our pages on Armenian business registration and taxation in Armenia set out the underlying filing obligations that generate these balances.

What can be attached, and what happens after 30 days

Attachment reaches money held in bank accounts and property that appears on a public register or in the taxpayer’s accounting records: real estate, vehicles and registered shareholdings. The total attached is capped at the amount of the liability, so a AMD 3 million debt does not authorize a freeze across every asset the company owns. In practice the bank freeze bites first, because it is instant and requires no valuation.

Individual debtors keep one significant protection that companies do not have. Under Article 64(1)(5) of the Law on Enforcement Proceedings, a citizen-debtor’s sole residence and the land adjoining it cannot be sold in compulsory auction where the starting auction price is at or below AMD 7,800,000 (about USD 19,750), a threshold set by Government Decision N 1709-N of 27 November 2025. Above that price the property can go to auction, and the protected minimum is returned to the debtor out of the proceeds.

If the debt is still outstanding 30 days after attachment, Article 431(13) of the Tax Code, added by HO-104-N, requires the SRC to forward the combined decision and the debt calculation electronically to the Compulsory Enforcement Service. Control of the file passes to an enforcement officer, whose powers come from the Law on Enforcement Proceedings, and compulsory enforcement carries its own fee charged on top of the tax debt.

An attachment on registrable property also stops a sale, because the cadastre will not register a transfer of an encumbered asset. From 30 August 2026 a second, independent gate applies to real estate under HO-407-N, which requires property tax clearance before the cadastre will register. The two obstacles come from different statutes and are cleared separately, as covered in our note on the property tax clearance requirement and on our Armenian real estate page.

Frequently asked questions

What to do this week

• Open the personal account card at file-online.tax.am and read the current balance, including any amount below AMD 200,000.
• If nobody in Armenia currently has access, begin the electronic signature and delegation process now. It runs on a scale of days, and the objection window is seven.
• If a reminder is already in the account, record the date it was placed there. Day one of the seven is the day after that date.
• If the window has closed and accounts are frozen, plan around payment as the release mechanism, with reassessment or refund pursued afterwards.

Last updated: 12 August 2026