Yerevan November 07
Naira Badalyan. Officials and experts from 20 countries of Eastern Europe and Central Asia gathered in Yerevan today to understand how to deal with modern challenges in the field of taxation, follow tax evasion and capital outflow from the country to offshore companies. The issues will be discussed at the IV regional meeting of the two-day IV regional meeting devoted to the system of preventing the erosion of the tax / tax base and the withdrawal of income / profits from taxation (BEPS) in Eastern Europe and Central Asia (EECA).
According to the head of the international programs and transfer pricing department of the RA State Directorate of Taxation, Nairui Avetisyan, in the age of electronic commerce and unrestricted movement of capital, the country's domestic legislation in a certain sense loses its relevance. Armenia is trying to resolve this issue, including with the help of international tax regulations. "The more the borders open, the closer the cooperation of the tax authorities," she said.
Back in June 2017, Armenia joined the 15th Action of the Organization for the Development of Economic Cooperation in the framework of a program to prevent the erosion of the tax base and the export of profits (BEPS), against transfer pricing. and the country's reliability is improved from the investor's point of view. Accession to the 15th BEPS protocol, as explained by Avetisyan, gives the tax authority of the country an additional lever of control in order to avoid tax evasion in by a foreign organization carrying out the activity of the Republic of Armenia, proving that the company's profit is formed in Armenia and, consequently, it is subject to taxation in Armenia. "The idea of BEPS is that the tax is payable in the country where additional value is created", – she said. At the same time, Armenia will avoid the fate of becoming a country for money laundering.
Today, already with 46 countries, Armenia has agreements against double taxation. Citizens and enterprises of the republic working abroad pay taxes there, and vice versa, the last agreement was recently signed with Israel. Purpose of these agreements
– eliminate double taxation in foreign trade between the two states, prevent tax discrimination against economic entities of the parties, eliminate double taxation of property and income, and create a predictable and stable tax environment for business. In November of this year. An agreement with Switzerland is planned to be signed, which is expected to be signed next year. The conclusion of a similar document with Argentina, Portugal and South Korea is also expected.
It should be noted that the issue of excluding double taxation between Armenia and the USA has been discussed for over 20 years – since 1994, the RA government has repeatedly raised this issue. In 2000, already during the Armenian-American intergovernmental meeting, the question was raised about the need to conclude an agreement. Since then, although preparatory work has been carried out to conclude an agreement, in fact, the negotiations themselves have not started. The current agreement concluded between the Soviet Union and the United States, as stated in the Ministry of Finance, is overdue and irrelevant, only for the simple reason that the Republic of Armenia is not the successor of the USSR. The American side argues its refusal by the fact that it sees no difficulty for US companies from the absence of such a contract. Yerevan, however, believes that even in the absence of obvious difficulties at this stage, the elimination of double taxation can be a barrier to attracting mutual investments, since the prospect of paying taxes twice can scare off potential investors.