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The Government of the Republic of Armenia adopted the decision N 619-N of 8 June 2017 On Establishment of the List of International Development Organizations of the Republic of Armenia (The decision comes into effect from January 1, 2018). The practical significance of the decision is conditioned by the application of Article 114 of the new RA Tax Code, which will come into effect from January 1, 2018.

According to Article 114 of the Tax Code of Armenia
When determining the tax base of non-resident profit taxpayers operating in the Republic of Armenia through a resident income taxpayer and a permanent establishment, the gross income shall not be deducted,
1) the percentage of interest amounts accrued on loans and / or borrowings (including interest accrued within the framework of financial lease contracts) exceeding the double-fold of bank interest rate set by the Central Bank of Armenia as of December 31 of the tax year Matching amounts. For the purpose of applying this paragraph, the amounts of interest accrued on loans and (or) loans are compared with the amount corresponding to the double-fold of bank interest rate set by the Central Bank of Armenia, individually, according to each loan and / or borrowing
(2) The portion of the interest accrued during the tax year on loans borrowed from entities not considered to be a bank or a credit organization exceeding the amount of tax year,
a. For a Corporate taxpayer (excluding banks and credit organizations), double the positive value of equity as of the last day of the tax year,
b. A bank or a lending institution, nine fold of the positive value of equity as of the last day of the tax year,
In the event of a negative amount of equity available at the end of the tax year, the amount of interests accrued during the tax year on loans borrowed from a bank or non-credit organization is not deducted from the gross income when determining the tax base of the profit taxpayer.
For the purposes of this paragraph, equity is calculated as the difference between the assets and liabilities calculated in the manner prescribed by the Code.
The provisions of this paragraph shall not apply to the amounts of interests accrued on loans received from international development organizations included in the list defined by the Government of the Republic of Armenia, as well as the amounts accrued on the funds attracted through the public placement of debt securities.
Based on Article 114 (1) (2) of the RA Tax Code, the Government of the Republic of Armenia decides:
 Establish a list of international development organizations in accordance with the Annex, for which the maximum allowable non-deductible rate for profit taxation shall not apply to the amount of interestsaccrued on loans received, as well as to the amount of interest accrued on publicly traded debt instruments.


The list of international development organizations

1. United States Agency for International Development
2. Overseas Private Investment Corporation
3. Black Sea Trade and Development Bank
4. World Trade Organization
5. Asian Development Bank
6. Austrian Development Agency
7. International Atomic Energy Agency
8. International Monetary Fund
9. African Development Bank
10. Multilateral Investment Guarantee Agency
11. Belgian Technical Coperation
12. KfW Banken gruppe
13. Deutscհe Gesellscհaft fur Internationale Zusammenarbeit
14. International Fund for Agricultural Development
15. Danisհ International Development Agency
16. Transport Corridor Europe-Caucasus-Asia
17. Swiss Agency for Development and Cooperation
18. Spanish Agency for International Cooperation
19. Italian Development Cooperation Programme
20. Canadian International Development Agency
21. Millennium Cհallenge Corporation
22. World Bank Group
23. European Fund for Southeast Europe
24. Japaո International Cooperation Agency
25. United Nations Conference on Trade and Development
26. Nations Industrial Development Organization
27. United Nations Economic Comission for Europe
28. United Nations Children's Fund
29. United Nations Development Programme
30. United Nations Environment Programme
31. Food and Agriculture Organization of the United Nations
32. United Nations High Commissioner for Refugees
33. United Nations
34. Department for International Development
35. International Organization for Migration
36. International Red Cross
37. Inter-American Development Bank
38. International Finance Corporation
39. Japaո Bank for International Cooperation
40. European Investment Bank
41. World Assocation of Investment Promotion Agencies
42. Swedish International Development Cooperation Agency
43. World Food Programme
44. Organization of the Black Sea Economic Cooperation
45. European Bank for Reconstruction and Development
46. International Bank for Reconstruction and Development
47. Organisation for Economic Co-operation and Development
48. Save the Children
49. Organization of Petroleum-Exporting Countries
50. French Development Agency

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