Որտե՞ղ պետք է տեղավորել ձեր հաջորդ 20 ծրագրավորողներին։ Հայաստանն ընդդեմ Վրաստանի, Սերբիայի և ԱՄԷ-ի

Armenia taxes qualifying high-tech activity at 1% of turnover and can reimburse 60% of the personal income tax computed on qualifying new hires; Georgia’s International Company status charges 5% on profit and 5% on qualifying employment income; Serbia exempts 70% of salary tax and all pension and disability contributions on qualifying R&D time; the UAE charges 0% on qualifying free-zone income and 9% on the rest. Every one of those figures carries eligibility conditions that decide whether your company ever sees the number, and three of the four attach conditions to the individual employee as well as to the entity.

What actually drives three-year employer cost

Six inputs decide what a 20-person engineering team costs an employer over three years: gross salary, employer social contributions, the tax charged on employment income, the corporate tax on the entity’s own margin, the cost of forming and maintaining the entity, and the cost of losing an incentive you had assumed. The last of those is the one companies model least and lose most on. In the UAE, a breach of the qualifying conditions removes free-zone status from the start of the affected tax period and for the following four tax periods, so a single misclassified revenue line can cost five years of the 0% rate.

The second structural point is where eligibility attaches. Armenia’s 1% rate attaches to the activity that generates the income. Armenia’s 60% support attaches to the entity’s turnover composition and to each employee’s prior employment history. Serbia’s relief attaches to the share of each employee’s working time spent on qualifying R&D and to who owns the resulting intellectual property. Georgia’s status attaches to the enterprise and is granted by government decision. A per-head cost model that applies one blended rate across a team will misstate all four.

Our research for this piece verified the legal cost drivers against primary sources in each jurisdiction. It did not produce sourced salary benchmarks for the four countries, so the salary input below has to come from your own offer data.

Armenia: what a company actually qualifies for

The 1% turnover tax

Tax Code Article 258(1), table item 8, applies 1% to income from activities on the Government’s high-tech list. The wording comes from HO-500-N Article 1, adopted 4 December 2024, and Article 2 makes it applicable from 1 January 2025 through 31 December 2031. Government Decision GD 142-N of 13 February 2025 supplies the activity list. There is no 90% qualifying-turnover condition attached to this rate and no requirement to enrol with the Ministry of High-Tech Industry to use it. One older statement in circulation says the opposite; it conflicts with the legislation.

Two qualifications matter for a hiring decision. The ordinary turnover-tax eligibility, election and exclusion rules under Article 254 still apply, so a company is not inside the regime merely because its activity appears on the list. And the 1% applies to qualifying activity income, not automatically to every receipt of a qualifying business. Sharing an activity list with the support programme described next does not import that programme’s conditions into the rate. Our guide to the 1% IT turnover tax covers the eligibility and timing mechanics in detail.

The 60% PIT support programme, which is a different thing

HO-498-N Article 5(4)(1) provides support equal to 60% of the personal income tax computed on a qualifying new employee. Article 3(1)(5) requires qualifying high-tech turnover to be at least 90% of declared sales turnover during the support reporting period. HO-221-N, which amended the law, was adopted 7 May 2026, took effect 30 May 2026, and applies to reporting periods beginning 1 January 2026.

The “new employee” test has a four-year lookback measured over the four years preceding the year of hiring. Current procedure also carries a transitional exclusion covering the period from 31 December 2024 to the date of application, for applications submitted through 31 December 2028. The status lasts three years and is employee-based, so it does not restart each time the person changes employer; GD 450-N, Annex 1, paragraph 3(1), as revised in July 2026, states this expressly.

Where a previous employer has already claimed and received the support for that same employee, the published texts do not settle whether a subsequent employer can claim the balance of the three-year window. The procedure preserves status across an employer change, while HO-221-N Article 8(2) addresses a later claim only in the case where the former employer has not received support. Two independent primary-source checks reached the same open question. Treat unrestricted portability as unconfirmed when you model the cost of hiring developers who already have Armenian high-tech sector history.

On registration, the precise position is worth getting right because it is commonly misstated. Application is electronic: GD 450-N, Annex 1, paragraphs 10 to 14, requires application through the Ministry’s platform with identification through YesEm. HO-498-N Article 10 establishes a high-tech sector administrative register within that platform, populated from public-authority information and business reports. No separate prior enrolment or certification step of the kind the old IT-certificate regime required was found in the current texts. Describing the platform application as “High-Tech Registry registration” conflates two different things.

Three further conditions shape who can claim. Armenian-registered branches and representative offices of foreign entities are expressly eligible, which is unusual among the four jurisdictions here. Civil-law remuneration arrangements are excluded, and an employee is defined by an employment contract or an individual hiring act, so a contractor roster will not qualify. Article 5(9) permits support under both the general and the turnover-tax systems during 2025 to 2031, but continued support after the third calendar year following the commencement year requires the general system, which is a timing trap for a company that elected the 1% regime at formation.

One wording caution. “60% PIT reimbursement” is shorthand. Article 5(8) uses a reference amount of 20% of salary for employees who benefit from the separate 10% R&D income-tax rate, and Ministry guidance distinguishes employer support for new employees from migrant support, which the employer must pass through to the employee.

The 200% salary deduction

Tax Code Article 123(2), introduced by HO-499-N Article 6 and running from 1 January 2025 through 2031, allows an additional 200% deduction of qualifying professional salaries, on top of ordinary salary deductibility. It is available only under the general profit-tax regime, is restricted by a prescribed list of professional work, requires the taxpayer to be engaged in high-tech activity with de minimis other income, and excludes foreign citizens and stateless persons without Armenian residence rights. The deduction is generally capped at 50% of the tax base before the deduction. A qualifying R&D taxpayer can escape that ceiling and may hold up to 10% other income. This is a conditional deduction that rewards a particular cost structure, so it changes the answer only for companies whose Armenian entity is substantially an engineering operation. Հարկերը Հայաստանում sets out how the regimes interact.

Where Armenia loses ground: Georgia, Serbia and the UAE

The three comparators below are matters of foreign law. The figures were verified against primary sources, and the application of any of them to your facts needs local counsel in the jurisdiction concerned.

Վրաստանը

Georgian Tax Code Article 23(7), (8) and (10) applies 5% to employment income paid by an International Company, 5% to its profit, and leaves dividends it pays untaxed at source and outside the recipient’s gross income under Georgian law. The 5% profit tax is not a conventional annual charge on retained accounting profit: Articles 23(9) to (11) link it to the distribution and specified-payment model in Article 97(1), with a 0.95 gross-up divisor, so the charge arises on distribution and on certain other payments.

Status is granted by government decision to a Georgian enterprise carrying on permitted activities. The revenue test is frequently quoted as “98% of revenue” and that is not the test. Permitted ancillary income, excluding VAT, must not exceed 2% of revenue from permitted activities, which makes the denominator permitted-activity revenue and the equivalent permitted share roughly 98.04% where those are the only two categories. Free Industrial Zone companies are excluded. Eligibility runs through a two-year experience route or a qualifying-parent route, the latter requiring a shareholder holding more than 50% with qualifying experience. No fixed headcount or revenue minimum was found, though Ordinance 619 of 8 October 2020, Annex 1, Article 2(2), requires Georgian core activities, adequate qualified personnel and operating expenditure in Georgia.

Սերբիա

Personal Income Tax Law Article 21i and Mandatory Social Insurance Contributions Law Article 45z, current through Official Gazette 80/2026 of 31 August 2026, exempt the employer from 70% of calculated salary tax and from 100% of pension and disability insurance contributions, both employee and employer portions. Both exemptions are proportional to time spent directly on qualifying R&D. Health and unemployment contributions are not covered.

The eligibility conditions are materially narrower than general payroll relief for technology employers. The employer must conduct the R&D for its own account and retain ownership of the resulting intangible assets. Direct technical participation qualifies and supervisory or support activity does not. The implementing Rulebook, Official Gazette 48/2022, requires the project activity to take place in Serbia, normally with at least 90% of the project’s R&D employees working in Serbia, subject to exceptions, plus project and working-time evidence. Serbian branches and representative offices of foreign companies are excluded, which is the opposite of Armenia’s treatment. A routine outsourcing operation that assigns resulting intellectual property to its clients should not assume eligibility. Other employment incentives generally cannot be combined for the same employee, although matching contribution relief and a separate double deduction of R&D costs are expressly accommodated.

ԱՄԷ-ն

Federal Decree-Law 47/2022, Articles 3(2) and 18, give a Qualifying Free Zone Person 0% on qualifying income and 9% on taxable income that is not qualifying income. The conditions are adequate substance, qualifying income, transfer-pricing compliance and no election into ordinary taxation. Ministerial Decision 229/2025, issued 28 August 2025 and replacing 265/2023, is the current qualifying-activities decision. It requires audited financial statements and limits relevant non-qualifying revenue to the lower of 5% of total revenue or AED 5 million.

For an engineering team the classification question is the whole exposure. Ordinary software development and consultancy for overseas clients is not automatically qualifying income merely because the services are exported. Qualifying income from copyrighted software intellectual property is computed on a separate expenditure-based nexus under Cabinet Decision 100/2023 and Ministerial Decision 229/2025. A Qualifying Free Zone Person does not receive the ordinary AED 375,000 zero-rate band against its taxable income. FTA Decision 6/2026 of 2 June 2026 adds an auditor’s agreed-upon-procedures report for qualifying distribution businesses in or from designated zones, for tax periods beginning on or after 1 January 2026. For groups in scope of the global minimum tax, the UAE domestic minimum top-up tax applies from financial years beginning 1 January 2025, using the EUR 750 million consolidated-revenue threshold met in two of the preceding four years, within a 15% minimum-tax framework. A headline 0% describes very little of what a large group will actually pay.

Recruitment, premises and compliance

The legal structure decides what you pay on each salary. It does not decide whether you can hire the people, and the operational choices below interact with the tax position in ways a cost model will miss.

Hiring form carries the sharpest consequences. Armenia’s support programme excludes civil-law arrangements outright, so a company that intended to start with a contractor roster and convert later will forfeit the support on every person hired that way, and the four-year lookback means the conversion does not repair it. Serbia’s relief depends on documented working time per project, so the timekeeping system has to be running before the first qualifying hour is worked. The UAE’s qualifying-income classification depends on what the team sells and to whom, which is a question for the commercial contracts and not the employment contracts.

Entity form divides the jurisdictions sharply. Armenia admits branches and representative offices of foreign entities into its support programme. Serbia expressly shuts them out. Georgia requires a Georgian enterprise with core activities, qualified personnel and operating expenditure in Georgia. A group that wants one legal entity serving several hubs will find that preference is compatible with Armenia and incompatible with Serbia. Our բիզնեսի գրանցում և գրանցված գործատու pages set out the Armenian routes and what each one supports.

Intellectual property ownership is the condition most often overlooked. Serbia conditions its relief on the employer conducting the R&D for its own account and retaining ownership of the resulting intangibles, so the standard arrangement in which a development subsidiary assigns everything to a parent or to clients can defeat the relief it was set up to capture. Armenia’s 1% rate and its PIT support do not impose that condition. Where the group’s IP holding structure is already fixed, that single fact can decide the comparison before any rate is applied.

Հաճախակի տրվող հարցեր

How to run this comparison against your own staffing plan

Work in this order, because each step can eliminate a jurisdiction before you spend time modelling it.

1. Fix the IP ownership question first. If the development entity will assign its output to a parent or to clients, Serbia’s relief is likely unavailable and the comparison narrows to three.
2. Fix the hiring form next. If the plan starts with contractors, Armenia’s 60% support is unavailable for those people permanently, and the four-year lookback blocks a later repair.
3. Test your revenue composition against each threshold: 90% qualifying turnover in Armenia, ancillary income within 2% of permitted-activity revenue in Georgia, and non-qualifying revenue below the lower of 5% or AED 5 million in the UAE.
4. Check entity form against the programme. Branches qualify in Armenia and are excluded in Serbia, and Georgia requires a Georgian enterprise with substance in Georgia.
5. Price the downside alongside the benefit. Build the five-year loss of UAE free-zone status into the model and count the Armenian employees whose prior high-tech history leaves their support status unconfirmed.
6. Only then apply salary data from your own offers, which is the input no published comparison can supply for your roles.

Վերջին թարմացումը ՝ 1 թվականի հոկտեմբերի 2026-ին