In Armenia, the criminal liability threshold for tax evasion has been raised to 30 million drams
19.05.2026,
18:19
In Armenia, the criminal liability threshold for large-scale tax evasion has been raised from 10 million to 30 million drams per tax year, the State Revenue Committee reported.
YEREVAN, May 19. /ARKA/. In Armenia, the criminal liability threshold for large-scale tax evasion has been raised from 10 million to 30 million drams per tax year, the State Revenue Committee reported.
The corresponding amendments and additions have been made to the Tax and Criminal Codes, as well as the Criminal Procedure Code.
According to the State Revenue Committee, large-scale tax evasion is now defined as tax evasion in excess of 30 million drams per tax year or more than 45 million drams over two consecutive tax years. Previously, the corresponding threshold was 10 million drams.
Especially large-scale tax evasion will be defined as tax evasion in excess of 50 million drams per tax year or more than 75 million drams over two consecutive tax years. Before the amendments, this figure stood at 20 million drams.
The State Revenue Committee noted that cases of tax evasion below the established thresholds will no longer be classified as a crime. Under the conditions stipulated by law, ongoing criminal proceedings for such cases may be terminated.
The amendments also clarify the procedure for reporting crimes involving tax evasion. Before submitting the materials to the competent authorities, the taxpayer must be given the opportunity to present explanations, evidence, and their position on the tax authority's investigation results.
Specifically, based on existing or received information, the tax authority will conduct a desk investigation. If the taxpayer agrees with the results and submits a calculation, including a revised one, the tax authority will not take any further action.
If the taxpayer does not respond to the investigation results or does not provide a substantiated explanation, the tax authority may initiate a case study and determine the tax liability within the framework of this study.
A notice of a crime will be sent in cases where a taxpayer fails to appeal an administrative decision of the tax authority within the prescribed timeframe, or where, following an administrative appeal, the decision remains unchanged in the required part.
However, according to the State Revenue Committee's clarification, a court appeal will not suspend the filing of a notice of a crime.
Exceptions are provided for cases where the immediate commencement of proceedings is necessary to preserve evidence, identify digital data, or conduct urgent procedural actions. Such a need must be confirmed by an authorized official of the tax authority.
The amendments also provide for changes to tax control tools. Specifically, the scope of information that can be used in a desk audit is expanded, including data from other sources.
Furthermore, the requirement for a "known transaction" is eliminated from the regulation of thematic studies, and the annual limit on their conduct is lifted. Instead of one study per year, up to three thematic studies can be conducted.
A separate set of amendments provides for the introduction of an alternative to the seizure of property in criminal proceedings. In cases established by law, the seizure of property may be replaced by a bank guarantee.
The State Revenue Committee stated that this mechanism is being introduced for the first time and will allow, in certain cases, the release of a taxpayer's property from seizure with the availability of a bank guarantee.
The list of assets that can be used as collateral is also being clarified. It includes securities, including bonds, property rights, and short-term bonds classified as money market instruments.
According to the State Revenue Committee, representatives of the private sector, the ministries of finance and justice, the Prosecutor General's Office, the Investigative Committee, the Central Bank, and the parliamentary standing committee on economic issues participated in the preparation of the reform. Deputy Prime Minister of Armenia Tigran Khachatryan coordinated the process.
The corresponding amendments and additions have been made to the Tax and Criminal Codes, as well as the Criminal Procedure Code.
According to the State Revenue Committee, large-scale tax evasion is now defined as tax evasion in excess of 30 million drams per tax year or more than 45 million drams over two consecutive tax years. Previously, the corresponding threshold was 10 million drams.
Especially large-scale tax evasion will be defined as tax evasion in excess of 50 million drams per tax year or more than 75 million drams over two consecutive tax years. Before the amendments, this figure stood at 20 million drams.
The State Revenue Committee noted that cases of tax evasion below the established thresholds will no longer be classified as a crime. Under the conditions stipulated by law, ongoing criminal proceedings for such cases may be terminated.
The amendments also clarify the procedure for reporting crimes involving tax evasion. Before submitting the materials to the competent authorities, the taxpayer must be given the opportunity to present explanations, evidence, and their position on the tax authority's investigation results.
Specifically, based on existing or received information, the tax authority will conduct a desk investigation. If the taxpayer agrees with the results and submits a calculation, including a revised one, the tax authority will not take any further action.
If the taxpayer does not respond to the investigation results or does not provide a substantiated explanation, the tax authority may initiate a case study and determine the tax liability within the framework of this study.
A notice of a crime will be sent in cases where a taxpayer fails to appeal an administrative decision of the tax authority within the prescribed timeframe, or where, following an administrative appeal, the decision remains unchanged in the required part.
However, according to the State Revenue Committee's clarification, a court appeal will not suspend the filing of a notice of a crime.
Exceptions are provided for cases where the immediate commencement of proceedings is necessary to preserve evidence, identify digital data, or conduct urgent procedural actions. Such a need must be confirmed by an authorized official of the tax authority.
The amendments also provide for changes to tax control tools. Specifically, the scope of information that can be used in a desk audit is expanded, including data from other sources.
Furthermore, the requirement for a "known transaction" is eliminated from the regulation of thematic studies, and the annual limit on their conduct is lifted. Instead of one study per year, up to three thematic studies can be conducted.
A separate set of amendments provides for the introduction of an alternative to the seizure of property in criminal proceedings. In cases established by law, the seizure of property may be replaced by a bank guarantee.
The State Revenue Committee stated that this mechanism is being introduced for the first time and will allow, in certain cases, the release of a taxpayer's property from seizure with the availability of a bank guarantee.
The list of assets that can be used as collateral is also being clarified. It includes securities, including bonds, property rights, and short-term bonds classified as money market instruments.
According to the State Revenue Committee, representatives of the private sector, the ministries of finance and justice, the Prosecutor General's Office, the Investigative Committee, the Central Bank, and the parliamentary standing committee on economic issues participated in the preparation of the reform. Deputy Prime Minister of Armenia Tigran Khachatryan coordinated the process.
