Armenia Transfer Pricing Documentation Requirements
Armenia requires a Master File and Local File where the cumulative value of a taxpayer's controlled transactions exceeds AMD 200 million, with no separate revenue threshold. Documentation is produced within 30 days, and penalties combine a percentage of the transaction value with a daily-accruing charge.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Cumulative controlled transactions > AMD 200m | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | HY / RU / EN | Yes (10% of transactions, plus 0.04% per day late) |
Local File Required | Same AMD 200m cumulative threshold (no revenue threshold) | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | HY / RU / EN | Yes (10% of transactions, plus 0.04% per day late) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Armenia deadline
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Scope of the documentation obligation
A Master File and Local File are required where the value of all controlled transactions conducted by the taxpayer during the year exceeds the cumulative threshold of AMD 200 million, approximately USD 500,000. There is no separate revenue threshold; the obligation turns solely on the aggregate value of the controlled transactions. The documentation is prepared to be provided to the tax authorities on request, within 30 days.
Distinctive features of the Armenian regime
The defining feature of the Armenian regime is the severity and structure of its penalty. A failure to submit the Master File or Local File on time when requested gives rise to a fine of 10 percent of the controlled transaction amount, and a further fine of 0.04 percent of that amount accrues for each day of late submission, so the consequence has both a substantial proportional component and an open-ended daily one. The obligation is gated by a single cumulative transaction threshold rather than a combination of revenue and transaction tests, which keeps the trigger simple. There is no published safe harbour and no transfer-pricing-specific return.
Benchmarking and comparables
Where there is insufficient information on uncontrolled transactions involving an Armenian party, foreign comparables are acceptable, provided the impact of economic circumstances and other comparability factors is analysed and adjustments made where necessary. A multi-year analysis over three years is preferred. There are no specific requirements on the frequency of a fresh search, although the best practice is to prepare a fresh benchmarking study each year. The limitation period for transfer pricing assessments is five years.
Frequently asked questions
How is the Armenian documentation penalty calculated?
A failure to submit a required file on time attracts a fine of 10 percent of the controlled transaction amount, plus a further 0.04 percent of that amount for each day of late submission.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.