Tributação e conformidade com criptomoedas na Armênia

Neste artigo:

• How crypto is taxed for individuals and companies
• The 1% reporting code from 1 December 2026
• The legal framework and the 31 January 2027 deadline
• CASP licensing, capital and state duty
• Banking for crypto businesses
• AML/KYC e a Regra de Viagem
• Classificação de tokens e o teste de Howey
• Crypto mining and the free economic zone
• Payment restrictions and the cash limit
• Stablecoins e DeFi
• High-tech benefits and residence for founders
• Cenários práticos
• Perguntas frequentes

Individuals in Armenia pay sem imposto de renda on selling ordinary crypto-assets such as bitcoin or ether, and 1% on selling an NFT or a coin created as a reward for mining or validating transactions. From 1 de Dezembro de 2026 tax agents report that 1% income under new codes 008.1 (Armenian citizens) and 108.1 (foreigners). Companies pay 18% profit tax on crypto profits.

Any business that offers crypto-asset services in Armenia needs a Central Bank of Armenia (CBA) licence. Operators that were already providing services on 4 July 2025 must be registered e licenciado por 31 de Janeiro de 2027 or stop; that deadline does not open a route for new entrants, who need the licence before they start.

How crypto is taxed in Armenia

The tax rules come from Law HO-175-N of 29 May 2025, in force 4 July 2025, which added crypto provisions to the Tax Code. Who sells, and what kind of asset is sold, decide the treatment; the venue (a licensed Armenian provider, a foreign exchange or a peer-to-peer deal) does not change the category of the income.

Individuals: ordinary crypto is exempt

Income an individual receives from disposing of a crypto-asset is listed among non-taxable incomes in Tax Code Art. 147(1)(16.1). It is an exemption, not a 0% rate, so there is no rate to apply and nothing to calculate on an ordinary sale of bitcoin, ether or a stablecoin. The exemption covers personal income. A sole entrepreneur is an income-tax payer only for personal income (Art. 140(2)), so crypto dealt in as part of a business is taxed with the business.

Individuals: 1% on NFTs and reward-created coins

Two kinds of asset are carved out of the exemption and taxed at 1% when an individual sells them (Tax Code Art. 150(9.1)):

• unique, non-fungible crypto-assets (NFTs); and
• crypto-assets created automatically as a reward for maintaining a distributed ledger or validating transactions, which covers coins received from mining and from validation.

The 1% is charged at the point of sale. The provisions set no deduction for the cost of acquiring the asset, which supports reading the 1% as charged on the disposal income; the law does not say this in terms, so for a large transaction ask the State Revenue Committee (SRC) for a clarification. Whether a coin bought on an exchange counts as “reward-created” because coins of that kind are also issued as rewards is not settled by the text.

Companies and business traders: 18% profit tax

Legal entities pay the standard 18% de imposto sobre lucros on crypto-derived profits. Crypto losses cannot be set against other business income (Art. 113). Crypto-asset service providers cannot use the simplified regimes: they are excluded from turnover tax and from the micro-enterprise regime.

NIF

Disposing of a crypto-asset is exempt from VAT (Tax Code Art. 64(2)(59)). Fees a provider charges for its services, such as exchange commissions and custody fees, are ordinary services and fall under the standard 20% VAT unless another exemption applies.

Valuation and records

Tax Code Art. 16.1 sets a crypto-asset’s initial value from its USD or EUR price on an exchange included in a Government-approved list, converted to AMD at the CBA rate published before 16:00 on the relevant day. A draft list (e-draft 10028) proposed eight exchanges, including Binance, Coinbase, Kraken and OKX. Whether the final Government decision has been adopted could not be confirmed in November 2026: the e-draft page shows no decision number or date, and no adopted list has been found on ARLIS.

Art. 55 accepts supporting documents that are not formal settlement documents as evidence of crypto income and acquisition costs. In practice keep exchange exports, wallet addresses and transaction hashes, dates, quantities, prices and fees, and evidence that separates purchased coins from reward-created coins and NFTs.

When individuals file

Resident Armenian citizens aged 18 or over file a personal annual income return. For 2026 income the window runs from 2 de março a 1 de julho de 2027 inclusive (Tax Code Art. 156(4) and (4.1)). Exempt crypto income does not create a tax to pay; 1% income that no tax agent withheld is declared and paid by the individual.

The 1% reporting code from 1 December 2026

SRC Order 1003-N, adopted 25 September 2026 and published 29 September 2026, amends Order 300-N on the monthly tax-agent return. It adds line 8.1, “income received for the disposal of crypto-assets”, with code 008.1 at 1% for Armenian citizens and code 108.1 at 1% for foreign persons. The same code is added to the income statements and the certificate of income and tax withheld. These crypto provisions take effect on 1 de Dezembro de 2026, the first day of the third month after publication; the rest of the order follows on 1 February 2027 and 1 June 2027.

The order defines the income narrowly: disposal of non-fungible crypto-assets and of crypto-assets created automatically as ledger or validation rewards. It matches the 1% category the Tax Code already had since July 2025. It does not tax ordinary crypto trading, and it creates no new rate. The two columns follow citizenship: Armenian citizen or foreigner.

The code is used by a tax agent, meaning an Armenian-registered organisation, sole entrepreneur or notary that pays the income (Tax Code Art. 29(1) and 152(1)). Whether a crypto-asset service provider is the tax agent on a given trade depends on whether it pays the income, for example by buying the asset for its own account, or only passes the order on. The law contains no rule that every provider withholds 1% on every customer trade, and ordinary exempt disposals are not reported as 1% income.

The legal framework and the 31 January 2027 deadline

The Law on Crypto-Assets (HO-159-N) was adopted on 29 May 2025 and took effect on 4 July 2025. It defines a crypto-asset as property based on cryptography that has value or certifies a right and is transferred and stored only through distributed-ledger technology. Tokens that qualify as securities, derivatives, fund units or deposits fall outside it. The CBA is the sole supervisor and issued its implementing regulations with effect from 31 January 2026.

A licensed crypto-asset service provider (CASP) is a joint-stock company or limited liability company holding a CBA licence (Art. 17(2)). Banks, investment firms, investment fund managers and certain other regulated institutions may provide specified crypto services with CBA authorisation under Art. 18, without setting up a separate CASP. Foreign providers cannot serve Armenian customers remotely: they must work through an Armenian subsidiary or a CBA-authorised branch (Arts. 21 and 22).

Who the 31 January 2027 deadline applies to

Art. 94(2), as replaced by Law HO-515-N of 17 December 2025, gives a one-year transition only to persons that were already providing crypto services on 4 July 2025. The CBA reminded them in a notice of 14 September 2026 that after 31 de Janeiro de 2027 providing or offering crypto services without registration and a licence is not permitted.

• pessoas jurídicas active on 4 July 2025 must be registered and licensed by 31 January 2027, or stop providing and offering crypto services. A company reorganised only by changing its legal form is covered.
• Empreendedores individuais active on 4 July 2025 could continue for the year and must then stop. A licence goes only to a joint-stock or limited liability company, so a sole entrepreneur who wants to continue needs a company that obtains the licence.
• Novos participantes have no transition. Incorporating a company, opening a bank account or filing an application does not permit a new business to start; it needs the licence first (Art. 17(1)).
• A aplicação pendente does not extend the deadline: neither the law nor the CBA notice provides for that.

The CBA publishes a list of ten persons (nine companies and one sole entrepreneur) to whom the cash exception in Art. 6.1(3) of the Law on Non-Cash Transactions applies. That list is not a licence register: it gives no licence numbers or dates. The CBA has not published a count of fully licensed CASPs, so this page does not state one.

CASP licensing, capital and state duty

To run a crypto exchange in Armenia you need a CBA licence for operating a trading platform, held by an Armenian JSC or LLC, with regulatory capital of at least AMD 70,000,000 (about USD 193,700). CBA Regulation 7/02 (Resolution 228-N, in force 31 January 2026) sets the floors by service:

These amounts are floors. Paragraph 7 of the regulation sets the minimum total capital at the highest of the fixed floor, 25% of fixed costs, and, for issuers of asset-referenced tokens, 2% of average reserve assets (3% once the tokens have at least 50,000 holders in Armenia, measured on the prior calendar year’s daily average). It is ongoing regulatory capital, so it has to be maintained after the licence is granted.

A CASP pays an annual state duty of AMD 500,000 (about USD 1,380): 500 times the base duty of AMD 1,000 (about USD 2.80), under item 5.13 of the Law on State Duty. Branches and representative offices of foreign providers pay their own duties under items 5.14 and 5.15.

Processo de licenciamento

Offer documents (white papers)

Regulation 7/04 requires an offer document for public offerings of crypto-assets, disclosing the technology, the rights attached, risks and conflicts. Offerings of AMD 20,000,000 (about USD 55,300) or less over 12 months are exempt. Persons that made public offerings before the regulation took effect had until 30 de Abril de 2026 to draw up, publish and submit compliant documents; that deadline has passed.

For a side-by-side view of licence, capital and timeline, see Armenia or Montenegro for a crypto business. Company formation for a CASP is covered in Cryptocurrency and blockchain company formation and CASP licensing in Armenia.

Banking for crypto businesses

Armenian banks treat crypto businesses as a restricted category. Since 31 January 2026 they may refuse or close accounts of crypto businesses that are not registered and licensed by the CBA, and no rule obliges a bank to open an operating account for a licensed provider either. Each bank decides case by case, so plan the licence before relying on an Armenian operating account. Payment-processing options are set out in Payment gateways and fintech solutions for businesses in Armenia.

AML/KYC e a Regra de Viagem

CASPs are reporting entities under the AML/CFT Law (HO-80-N, as amended by HO-180-N). They must carry out customer due diligence, monitor transactions, report suspicious activity and keep records for five years.

AML Law Art. 20.1 imposes Travel Rule duties on crypto-asset transfers. CBA Decision 12-N applies them to transitional operators, who must collect and pass on transaction hashes, timestamps, counterparty wallet addresses and customer identification data. Transfers missing the required information must be rejected (Art. 27). The CBA’s Financial Monitoring Center guidance of October 2025 flags self-hosted wallets, decentralised trading platforms and mixers as higher-risk factors.

Classificação de tokens e o teste de Howey

A token that meets the definition of a security, derivative, investment fund unit or bank deposit falls outside the Crypto-Assets Law and is regulated under the Securities Market Law or the Investment Funds Law.

The CBA applies its Official Clarification No. 3 (2012), which uses the four-part Howey test to decide whether a token is an “investment agreement”: an investment of money, in a common enterprise, with an expectation of profit, derived from the efforts of others. Fund managers may provide crypto portfolio management and advice under the Investment Funds amendments (HO-176-N). Convertible notes were added to Armenian law in May 2025 (Civil Code amendment HO-114-N and JSC Law amendment HO-116-N), which gives a legal basis for debt-to-equity token structures.

Crypto mining and the free economic zone

Government Decision 1591-N (October 2024) lists “creation of crypto-assets (bitcoins and other altcoins) online” as a main activity for free economic zones (FEZ). The ECOS FEZ in Hrazdan, Kotayk, established in 2018, is the operating zone used for industrial mining. Mining itself does not need a CASP licence; selling mined coins to customers through your own platform does.

FEZ operators are also exempt from property tax on public and production real estate in the zone that they own or use (Art. 230(1)(14)), and imported equipment can enter under the free customs zone procedure, subject to EAEU customs rules. Art. 64(2)(23) sits among the VAT exemptions; the 0% rate in Art. 63(3) covers only the transactions listed in Art. 65.

Art. 126 was amended by Law HO-383-N of 3 July 2026, with effect from 1 January 2027; the scope of that amendment for mining operators has not been reviewed for this guide. No 2027 electricity tariff decision has been published. Real-presence rules apply: core income-generating work must be done inside the zone, core activities cannot be outsourced, and operators are held to their business plan on staff and spending. There is no fixed minimum investment.

The 1% rate on reward-created coins is a personal income tax. It applies when an individual sells mined coins; a mining company is taxed on its profit, which inside the FEZ falls under the exemption above.

Payment restrictions and the cash limit

The Armenian dram is the only legal tender. Paying with crypto-assets in Armenia is prohibited by Civil Code Art. 142(5), in force 4 July 2025; the only exception is e-money tokens issued under the Crypto-Assets Law. The Civil Code also bars settling obligations in crypto and exchanging crypto-assets for non-crypto goods or property.

Crypto purchases and sales must be non-cash. From 1 January 2026 until 1 January 2028, Art. 6.1(3) of the Law on Non-Cash Transactions allows a crypto transaction in cash of up to AMD 300,000 (about USD 830) if it is done with or through a crypto-asset service provider that verifies the customer’s identity and records the terms.

Stablecoins e DeFi

Issuing asset-referenced tokens, the category most stablecoins fall into, needs the highest capital floor (AMD 200,000,000) plus the reserve-based component described above. The IMF reported that the April 2026 structural benchmark to adopt dedicated stablecoin rules was not met; whether those rules have since been adopted could not be confirmed. Fiat-pegged tokens may also qualify as e-money tokens, the one type of token that can be used to pay.

The Crypto-Assets Law regulates identifiable providers. Fully decentralised, non-custodial protocols have no specific framework, and there is no mechanism yet for applying KYC duties to autonomous code.

High-tech benefits and residence for founders

Software and blockchain-development companies that are not CASPs may qualify under the High-Tech Sector Support Law (HO-498-N). The main measure returns 60% do imposto de renda on the salaries of qualifying new professional employees and of qualifying migrant professionals. At least 90% of declared sales turnover must come from eligible high-tech activities. Qualifying firms can also use a 1% turnover-tax rate set in the Tax Code. CASPs are excluded from turnover tax; whether they can use the employee measures depends on the law’s activity definitions, and blockchain development qualifies only when it is classified under an eligible code such as software development.

Como 1 Novembro de 2026, Law HO-11-N has added an entrepreneurial residence ground to the Law on Foreigners (Art. 29.4). A foreigner qualifies by investing at least AMD 2,000,000 (about USD 5,530) in an Armenian company’s charter capital or in shares or securities of that value; a sole entrepreneur qualifies with AMD 1,000,000 (about USD 2,770) in their accounts, or AMD 1,000,000 of turnover in the 60 days before applying. The residence status can end if the capital is withdrawn or falls below AMD 1,000,000, or if the SRC has no tax data from the business within 180 days. The track is open to any business, crypto or not.

Cenários práticos

Perguntas frequentes