Last updated February 2026
TL;DR
- Non-resident individuals selling personal property (including real estate and land) in Armenia generally pay zero tax under Art. 147(1)(16) and Art. 147(1)(38) of the Tax Code. Share sales are also exempt under Art. 149(1)(2), unless the anti-avoidance rule for real-estate-holding companies applies.
- Non-resident companies face 10–18% on the same transactions: 10% on real property gains, 18% on share sales (with a 2-year holding exemption), and 0% on listed securities (Tax Code, Art. 125(4)).
- The difference between holding assets personally vs. through a company can mean the difference between zero tax and 18% tax on the same sale — making structure a critical planning decision.
- All rates are subject to double tax treaty overrides where applicable.
If you own property, shares, or other assets in Armenia as a non-resident, the tax you pay when you sell depends on two things: what you are selling, and whether you hold it personally or through a company. This guide breaks down both regimes — personal income tax (PIT) for individuals and corporate income tax (CIT) for companies — so you can plan your exit before you need one.
Who counts as a non-resident for Armenian tax purposes
An individual is a non-resident if they spend fewer than 183 days in Armenia during a tax year and their center of vital interests is not in Armenia. A company is a non-resident if it is not registered (incorporated) in Armenia. Non-residents are taxed only on income from Armenian sources — not on their worldwide income (Tax Code, Art. 4 and Art. 141(1)(2)).
For a deeper look at how residency status is determined, see our guide to Armenia’s rules for foreign-sourced income and global taxation.
When does a sale trigger Armenian tax (sourcing rules)
A non-resident’s gain from selling an asset is considered Armenian-source income — and therefore taxable — in two situations (Tax Code, Art. 107(3)(5)):
For assets other than shares and investment securities: the gain is from alienation of assets physically located in Armenia. This covers real estate, vehicles, equipment, and any other tangible property situated in the country.
For shares and investment securities: the gain is from alienation of shares in an Armenian-registered company or securities issued by an Armenian-registered company. The physical location of the seller is irrelevant — what matters is whether the issuing company is Armenian.
One exception: if the gain is attributable to a permanent establishment’s business activity, it falls under the PE rules instead (Art. 133).
Non-resident individuals: PIT on asset sales
The PIT regime for non-resident individuals selling Armenian assets is notably generous. Several broad exemptions mean that most asset sales by non-resident individuals are either tax-free or taxed at low rates.
Personal property: exempt
Income from alienation of property owned by an individual who is not a sole proprietor or notary is exempt from PIT (Tax Code, Art. 147(1)(16)). This exemption applies regardless of the seller’s residency status and regardless of who the buyer is. It covers real estate, vehicles, personal belongings, and any other property held for personal (non-business) purposes.
A few narrow exclusions apply: sales by developer-individuals of apartments or buildings in multi-apartment projects, sales of NFTs (unique crypto-assets), and sales of crypto-assets created as mining or validation rewards.
Land plots: exempt
Income from alienation of land plots is exempt from PIT regardless of the land’s designated purpose (Tax Code, Art. 147(1)(38)). This is a separate exemption from the personal property rule and applies even if the land is agricultural, commercial, or industrial.
Shares and securities: generally exempt
Income from alienation of shares, participatory interests, or investment securities is exempt from PIT (Tax Code, Art. 149(1)(2)). This is a broad exemption that covers sales of ownership stakes in Armenian companies — with one important exception described in the anti-avoidance section below.
When PIT does apply
| Asset type | Rate | Provision |
|---|---|---|
| Shares in real-estate-holding companies (sold within acquisition year + 3 tax years) | 10% | Art. 149(2)(3), Art. 150(15) |
| Developer-individual selling apartments/buildings | 20% | Art. 150(11) |
| NFTs and mining-reward crypto-assets | 1% | Art. 150(9.1) |
| Dividends (non-listed shares) | 5% | Art. 150(8) |
| Rental income | 10% (+ additional 10% above AMD 60 million/year) | Art. 150(7) |
| Interest (bank deposits, publicly offered debt) | 10% | Art. 150(5.1) |
| Interest (other) | 20% | Art. 150(5) |
| Royalties | 10% | Art. 150(6) |
Important nuance: the personal property exemption (Art. 147(1)(16)) applies only when the individual is not conducting entrepreneurial activity. If a non-resident individual habitually buys and sells Armenian real estate in a pattern that resembles business activity, the tax authorities could recharacterize the transactions as entrepreneurial income — removing the exemption and potentially applying the general 20% PIT rate or even CIT rules (Tax Code, Art. 4(1)(24)).
Non-resident companies: CIT on asset sales
Non-resident companies without a permanent establishment in Armenia face a different — and generally less favorable — tax regime. The tax base is gross income with no deductions permitted (Art. 105(1)(4)), and the applicable rates are set out in Art. 125(4).
| Asset type | Rate | Provision |
|---|---|---|
| Real property located in Armenia | 10% on gain | Art. 107(3)(5), Art. 125(4)(2) |
| Shares / participatory interests (held ≤ 2 tax years after acquisition year) | 18% on gain | Art. 125(4)(4) |
| Shares / participatory interests (held > 2 tax years after acquisition year) | Exempt | Art. 108(1)(26) |
| Securities (other than shares/participatory interests) | 0% | Art. 125(4)(4) |
| Other movable assets in Armenia | 10% on gain | Art. 107(3)(5), Art. 125(4)(2) |
| Government bonds (interest, discount, alienation) | Exempt | Art. 126(5) |
| Listed securities (exchange-traded, through Dec 31, 2027) | Exempt | Art. 126(5.1) |
| Dividends | 5% | Art. 125(4)(3.1) |
| No cost basis documents available | Tax on full sale price | Art. 107(3)(5)(f) |
The 18% rate on shares and participatory interests is the headline number that most non-resident corporate investors need to plan around. It applies specifically to ownership stakes in other organizations — not to securities generally. Bonds, investment fund certificates, and other non-equity securities are taxed at 0%.
Side-by-side comparison: individual vs. corporate holdings
This is where structure becomes a planning tool. The same transaction can produce dramatically different tax outcomes depending on whether the seller is a non-resident individual or a non-resident company.
| Transaction | Non-resident individual | Non-resident company |
|---|---|---|
| Sell an apartment in Yerevan | Exempt (Art. 147(1)(16)) | 10% on gain (Art. 125(4)(2)) |
| Sell a land plot | Exempt (Art. 147(1)(38)) | 10% on gain (Art. 125(4)(2)) |
| Sell shares in Armenian LLC (held 1 year) | Exempt (Art. 149(1)(2)) | 18% on gain (Art. 125(4)(4)) |
| Sell shares in Armenian LLC (held 3+ years) | Exempt (Art. 149(1)(2)) | Exempt (Art. 108(1)(26)) |
| Sell shares in RE-holding company (held 1 year) | 10% (Art. 149(2)(3)) | 18% (Art. 125(4)(4)) |
| Sell listed shares on Armenian exchange | Exempt (Art. 149(1)(2)) | Exempt through 2027 (Art. 126(5.1)) |
| Receive dividends (non-listed) | 5% (Art. 150(8)) | 5% (Art. 125(4)(3.1)) |
| Sell government bonds | Exempt (Art. 149(1)(1)) | Exempt (Art. 126(5)) |
The pattern is clear: for most asset sales, non-resident individuals pay significantly less — often nothing — compared to non-resident companies selling identical assets. The exception is dividends, where both pay 5%, and government bonds and listed securities, where both are exempt.
Holding period exemptions and anti-avoidance rules
CIT: 2-year holding period for shares
Under Art. 108(1)(26), gains from alienation of shares, participatory interests, or equity stakes are exempt from CIT if the sale occurs after two full tax years following the tax year that includes the acquisition date. This is a calendar-year test, not a 24-month count.
Example: shares acquired on March 15, 2024 (tax year 2024). The two following tax years are 2025 and 2026. The sale is exempt from CIT starting January 1, 2027.
This exemption applies to non-resident companies and effectively reduces the 18% share-sale rate to 0% for patient investors.
PIT: anti-avoidance rule for real-estate-holding companies
The PIT securities exemption (Art. 149(1)(2)) does not apply when the seller is disposing of shares in a company whose assets consist of buildings, apartments, houses, or other structures, and the sale occurs within the acquisition year or the three following tax years (Art. 149(2)(3)).
Example: shares in a real-estate-holding LLC acquired in 2024. The anti-avoidance rule applies through the end of 2027 (acquisition year 2024 + three tax years 2025, 2026, 2027). Sales from January 1, 2028 onward are exempt.
During the restricted period, the gain is taxed at 10% (Art. 150(15)). This rule exists to prevent individuals from wrapping real estate in a company and selling the company shares tax-free instead of selling the property directly.
Note the different holding periods: CIT requires 2+1 tax years for general share exemption; PIT anti-avoidance for RE-holding companies requires 3+1 tax years. Both use calendar years.
How tax is collected: withholding and self-assessment
When the buyer of an Armenian asset is an Armenian company, sole proprietor, or notary, the buyer acts as the tax agent and is responsible for calculating and withholding the tax from the payment to the non-resident (Tax Code, Art. 132 for CIT, Art. 152 for PIT). The liability to pay the tax rests with the buyer, not the seller.
If an exemption applies — for example, the personal property exemption under Art. 147(1)(16) for individuals — the tax agent does not withhold. The exemption removes the tax obligation entirely; there is no withholding followed by a refund.
When there is no tax agent (for example, when both buyer and seller are individuals, or when the buyer is located outside Armenia), the non-resident must self-assess and pay the tax directly (Art. 130(5) for CIT, Art. 154(2) for PIT).
For CIT, the withholding is on a cash basis — triggered by actual payment, offset, debt restructuring, assignment, or debt forgiveness (Art. 132(2)). The tax withheld by the agent is considered the final CIT liability (Art. 130(4)).
Cost basis rules and the documentation trap
For non-residents, the gain (asset value appreciation) is the positive difference between the sale price and the book value of the asset (Tax Code, Art. 4(1)(36)). However, the ability to deduct your cost basis depends entirely on having proper documentation.
The Tax Code establishes a hierarchy of cost basis evidence (Art. 107(3)(5)):
Acquisition documents exist: cost basis is determined from the acquisition, transfer, and placement documents (sub-point b). This is the standard case — purchase contracts, invoices, and similar records.
Only import/transfer documents exist: if there are no acquisition documents but the asset was imported into Armenia, cost basis is determined from customs declarations or import tax declarations (sub-point a).
Depreciable assets: gain is calculated based on the book value at the moment of alienation, using the alienator’s documents (sub-point c).
Revalued assets: if the asset was legally revalued and the revaluation affected the CIT base, the revalued amount is used (sub-point d).
No documents at all: the entire sale price is treated as the gain — zero cost basis (sub-point f). This is the worst-case scenario and is entirely avoidable with proper record-keeping.
The lesson is straightforward: keep your acquisition documents. A non-resident who cannot produce purchase records for a $500,000 property will be taxed on the full $500,000, not just the profit.
Special rules for listed securities and government bonds
Both individuals and companies benefit from exemptions on Armenian government bonds and exchange-listed securities:
Government bonds: interest, discount income at maturity, and gains from alienation are exempt for non-resident individuals (Art. 149(1)(1)) and non-resident companies (Art. 126(5)).
Exchange-listed shares: dividends and gains from alienation of shares listed on the Armenian stock exchange are exempt for non-resident companies through December 31, 2027 (Art. 126(5.1)). For non-resident individuals, the general securities exemption under Art. 149(1)(2) applies without a sunset date.
Exchange-listed bonds: interest income and gains from alienation are exempt under specified conditions and date windows. Bonds listed before January 1, 2025 follow one set of rules; bonds listed from January 1, 2025 through December 31, 2027 follow another (Art. 126(5.1), sub-points 3–6).
These provisions are designed to encourage capital market development in Armenia and represent a meaningful incentive for portfolio investors.
Double tax treaty relief
Armenia has double tax treaties with over 45 countries. Where a treaty applies, it may reduce or eliminate the Armenian tax on asset sales. Under Armenian law, treaty provisions prevail over conflicting domestic rules (Tax Code).
To access treaty rates, a non-resident typically needs to provide a valid certificate of tax residency from their home country. Treaty analysis is fact-specific and depends on the particular treaty’s provisions regarding capital gains, immovable property, and company shares.
If you are planning a significant asset sale, confirm whether a treaty exists with your country of residence and how it allocates taxing rights before closing the transaction.
FAQ
Do non-resident individuals pay capital gains tax when selling Armenian real estate?
Generally no. Under Art. 147(1)(16) of the Tax Code, income from alienation of property owned by a non-business individual is exempt from PIT. This applies regardless of residency status and regardless of who the buyer is. The exemption covers real estate, and a separate provision (Art. 147(1)(38)) exempts land sales specifically. The main risk is if your transaction pattern looks like business activity, which could remove the exemption.
What about non-resident companies — do they pay tax on property sales?
Yes. Non-resident companies pay 10% CIT on the gain (sale price minus documented cost basis) from selling property located in Armenia (Art. 125(4)(2)). If no cost basis documents are available, the entire sale price is treated as the gain and taxed at 10%.
Is there a holding period that makes share sales tax-free?
For non-resident companies, yes: shares held for more than two full tax years after the acquisition year are exempt from the 18% CIT (Art. 108(1)(26)). For non-resident individuals, share sales are generally exempt anyway (Art. 149(1)(2)), but if the company holds real estate, the exemption is suspended for the acquisition year plus three additional tax years (Art. 149(2)(3)).
Should I hold Armenian assets personally or through a company?
From a pure Armenian exit-tax perspective, personal ownership is generally more favorable — most asset sales by non-resident individuals are exempt, while companies face 10–18%. However, asset structuring involves considerations beyond exit tax: liability protection, management convenience, foreign ownership restrictions on land, ongoing compliance costs, and your home-country tax rules. We recommend discussing your specific situation with a tax advisor before making structural decisions.
Who is responsible for withholding the tax — the buyer or the seller?
When the buyer is an Armenian company, sole proprietor, or notary, the buyer acts as the tax agent and is responsible for calculating and remitting the tax. If an exemption applies, the tax agent does not withhold — there is no withholding followed by a refund. When there is no tax agent (e.g., both parties are individuals), the non-resident seller must self-assess and pay directly.
What happens if I don’t have purchase documents for my Armenian property?
Under Art. 107(3)(5)(f), if you cannot provide acquisition documents, the entire sale price is treated as your taxable gain — effectively a zero cost basis. This applies to companies; for non-resident individuals selling personal property, the exemption under Art. 147(1)(16) means the documentation issue is moot since the sale is exempt regardless.
Are government bonds and exchange-listed securities tax-free for non-residents?
Yes. Government bonds are fully exempt for both non-resident individuals (Art. 149(1)(1)) and companies (Art. 126(5)). Exchange-listed shares and bonds are exempt for non-resident companies through December 31, 2027 (Art. 126(5.1)), and for individuals the general securities exemption (Art. 149(1)(2)) applies without a sunset date.
Can a double tax treaty reduce or eliminate the Armenian tax?
Potentially yes. Armenia has tax treaties with over 45 countries, and treaty provisions prevail over domestic law. A treaty may reduce or eliminate Armenian tax on capital gains, depending on the specific treaty and the type of asset being sold. You will need a valid tax residency certificate from your home country to claim treaty benefits.
Planning an asset sale in Armenia? The tax outcome depends on your structure, holding period, and documentation — all things that can be optimized before the transaction closes. Contact our team for a confidential assessment and tailored advice.
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