International Tax

Our team is composed in the most part of tax advisors who are among the best specialists and who combine an in depth knowledge of Armenian and international tax law with many years of experience in contacts with the fiscal and tax administration.

Scope of our services

1. advisory of a tax planning nature, including:

• tax reviews aimed at identifying potential fields of tax planning
• optimising international tax structures
• assistance in creating and implementing tax structures
• assistance in estimating the costs of implementing new solutions
• advisory related to the tax aspects of the business activity of foreign enterprises in Armenia and Armenian enterprises abroad (branches, representative offices, partnerships)

2. advisory related to the tax aspects of a permanent establishment: 

• analysis of international tax structures from the point of view of a permanent establishment
• verifying or establishing the method of settlements between the headquarters and a permanent establishment
• establishing rules of allocating income to a permanent establishment and costs borne by the headquarter to a permanent establishment
• preparing documentation describing flows between the headquarters and a permanent establishment
• establishing rules for financing the activity of permanent establishment assistance in documenting settlements between the headquarters and a permanent establishment.

3. reviews and analysis of cross border transactions and payments, including: 

• analysis of tax structures in order to verify the correctness of the application of double tax treaties
• review and analysis of transactions from the point of view of particular provisions of the double tax treaties
• advisory and analysis regarding the tax implications of international transactions
• analysis of transactions from the point of view of the withholding tax obligation in Armenia and abroad, as well as assistance in minimising withholding tax obligations.