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13.4.3. Documentation Requirements

Disclosure Requirements

Taxpayers whose aggregate controlled transactions for a reporting year exceed AMD 200 million must file a notice with the tax administration by 20 April of the following year. The disclosure notice must contain information on the key areas of the taxpayer’s activity, the aggregate value of controlled transactions broken down by category including information on uncontrolled transactions, the countries of residence of the counterparties, the transfer pricing methods used, details of controlled transactions undertaken free of charge, as well as details of domestic controlled transactions.

Standard Documentation

The law provides for an obligation for taxpayers falling within the ambit of the transfer pricing rules to prepare and maintain adequate documentation in order to substantiate their transfer pricing policies. The documentation must be supplied to the tax administration within 30 days of their request.

In general, the transfer pricing documentation must contain the following:

  • General information: shareholder relationships, organizational and operational group structure, business operations;
  • Description of intercompany transactions: type and volume of transactions, intercompany contracts, and a list of parties to the intercompany transactions;
  • Functions and risks analysis: description of functions and risks assumed in relation to the intercompany transaction, contractual terms, business strategies, and value chain; and
  • Transfer pricing analysis: selection of the transfer pricing method, appropriateness of the method selected, calculation of the transfer price, list of comparables along with the sources of information, financial and any other relevant information of the company, and documentation of adjustment calculations.

Country-by-Country (CbC) Reporting

Armenia has to date not introduced any Country-by-Country reporting requirement under its domestic law. However, Armenia has joined the OECD Inclusive Framework, membership of which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.

Language of Documentation

The documentation may be submitted in Russian, English, or Armenian, provided an Armenian translation is submitted within 10 working days upon a request received from the tax authorities.