Other Tax Services

In the recent years tax authority has made a progress running the new practice of delivering explanations by official notifications, still, this does not cover the demand and often yields in terms of speed and simplicity of solutions. Our company tries to assist taxpayers in the assessment of tax consequences of the certain transaction. That is important for business from the point of planning financial flows, as well as for the use in the corporate and other scopes. Within this framework we have had the following cases:

• Financing schemes for establishment of new workplace through foreign investments, new shares deployment, provision of loans, commercial credit, etc.
• Equipment acquirement and import to Armenia, setup in Armenia, retraining of the staff, “tax component’’ calculation of post-delivery maintenance transaction taking into account involvement of companies of several countries.
• Transfer of the right to receive cash caused by credit obligations by bank
• Activity of a diplomat’s family member in Armenia
• The change of state registration of a foreign parent company
• Rendering public food services to employees (establishment of private cafeteria)
• Renting of real estate in Armenia belonging to a foreign entity
• Export and import to a Eurasian Economic Union member country, including cases based on commission agreement
• Provision and forgiveness of interest-free loans to natural and legal entities
• Joint operation agreements and the uniqueness of their application in Science, Research and Development field
• Financing of residential building construction through bill issues
• The annual tax reporting characteristics as a result of design and constructional works carried out by a branch of foreign company
• The involvement of resources on the part of Luxembourg and German banks and investment companies. The possibilities of optimization on the basis of national legislation and international tax agreements.
• The characteristics of customs value while importing according to the franchising contract
• Pecularities of grant programs' execution by foundations
• Import and/or manufacturing of materials that damage the nature։ Classification and taxation
• Cession and offset of obligations with the involvement of foreign legal entities
• Alienation of real estate below the cadastral value to the payer of turnover tax organization
• Alienation of property meant for production use owned by a natural person.
• Service provision via Internet and postal services in Europe by Armenian entity.
• Contracts at the border zone of Armenia and at the free economic zone.
• Other works

Observations of this kind are important for implementation of major investment projects. Main points are accuracy of tax consequences of foreign transactions from the point of Armenian national tax legislation and tax treaties. Problems usually arise in the application of international agreements and in such cases all components are examined: combination with national clause, international project budget lines, implementation of works under the nature and scope of the project, the accuracy of administrative information and preparation of tax reports, etc.

Tax consultancy on international transactions is most demanded among our international tax services, because local companies, even medium and sometimes small enterprises, also carry out transactions with foreign companies. Our consultancy refers to application of VAT 0% rate in Armenia, the mechanism and possibility to use the international treaty, the degree of complexity of document administration, taxes and custom duties paid at the border during import of goods into Armenia (including the leasing or those realized by factoring mechanism), specifics of transaction tax with entities in Eurasian Economic Union member states and so on.

Essential peculiarities are defined on tax declaration and related statements used by non-residents. This concerns especially the profit tax, as for other taxes it is necessary to take care of onetime package and registration system in advance reconciling it with the requirements of accounting legislation (e.g. accounting policy, the description of the projects implemented in RA, and preparation of materials with tax authority for determination of taxable profit in RA and choice of direct or indirect method for discussion, etc).

BDO in Armenia claims to be one of the leading organizations and centers in Armenia that can provide integral services on tax treaties in Armenian, English, Russian and French.

• Information on tax treaties of RA on evasion of double taxation
• Professional clarifications on clauses of OECD (Organization of Economic Cooperation Development) and UN (United Nations) model tax conventions
• Consultancy on the article of the treaty with a certain country
• Extracts and/or analytical references according to the fields, income types, etc
• Application of tax treaties in certain transactions or invest projects

Tax consulting on application of economic agreements of Armenia

Existence of international informational database, as well as experience of services rendered to foreign legal entities operating in different spheres, afford an opportunity to extend activity field and, besides the tax and accounting services, enter the related sphere: that is application of other international economic treaties-investments, field regulations, agreements of free economic zone, Agreements of World Trade Organizations and other bilateral and multilateral agreements.

Within international consulting we find this more complicated and responsible, at the same time more interesting sector. The problem is that national tax legislation of Armenia, especially its administrative users are not ready to accept the institutes and tools used in international tax practice. Optimal scheme of the investments in Armenia and/or projects implementation includes numerous factors, comparison and combination of different transactions, in particular

• planning usage of threshold norm terms defined by law and other opportunities keeping neutrality and optimality against business decisions
• use of international tax agreements in the framework of business decisions neutrality and optimization
• combination / association of some economic agreements, some services, tax treaties of several countries for economy of tax and administrative expenses permitted by law taking into consideration business habits circulation and other restrictions

Eurasian Economic Union provides free movement of products, services, capital and labor, as well as maintenance of systematic, coherent or consistent policy in the circumstances of single market. The member states of European Economic Union are Republic of Armenia, Republic of Belarus, Republic of Kazakhstan, Kyrgyz Republic and Russian Federation.

BDO in Armenia is specialized in the consultancy of the entrepreneurs of the member states of this organization, as well as participates in the consideration of issues, obstacles and regulations, as well as other normative acts in various platforms, including the platform of Advisory Committee of EEU Commission, the platform of the Union of Manufacturers and Businessmen of Armenia.

Special workshops are held on the application of EEU legislation, on customs, technical regulations, licenses and subsidies, application of indirect taxes etc.