TRANSFER PRICING FRAMEWORK IN ARMENIA Sample Clauses

TRANSFER PRICING FRAMEWORK IN ARMENIA. Under part 5 of Article 363 of the new Tax Code of Armenia, transfer pricing rules apply, if the sum total of all the controlled transactions of the taxpayer within the tax year exceeds AMD 200 million. The Tax Code defines Transfer Pricing as procedure for determination of financial indicators in controlled transactions. This definition implies that in order for transfer pricing rules to apply, it must be established that a transaction — supply of goods, sale of intangible property and/or provision of services — is controlled. Under part 1 of Article 363 of the Tax Code, a transaction is considered controlled if it is carried out between related taxpayers. The fact of relatedness, under part 3 of Article 363 of the Tax Code, is irrelevant in case a transaction is concluded between a resident taxpayer and taxpayers in offshore zones. Taxpayers, according to part 1 of Article 362 of the Tax Code, are deemed related in two cases: (1) one of the taxpayers is directly or indirectly involved in the management, control of the other taxpayer or has a participation in the authorized or share capital of the other taxpayer; (2) the same taxpayer is directly or indirectly involved in the management, supervision of two or more taxpayers or has a participation in their authorized or share capital. A more practical view of the meaning of transfer pricing, as defined under the new Armenian tax regulation, can be provided through a hypothetical scenario. ACo, an Armenian company, directly possesses 25 percent shares in the authorized capital of BCo, company operating in Georgia. XXx produces keyboards and sells them to BCo. Under point 1 of part 2 of Article 362 of the Tax Code, if one taxpayer has 20 or more percent shares in the authorized capital of another taxpayer, it is considered to be involved in the management, control of or to have participation in the authorized capital of the other taxpayer. Thus, the Armenian tax authority will have the grounds prescribed by the Tax Code to apply the rules of transfer pricing and determine the financial indicators in the transaction. Under point 2 of part 1 of Article 361 of the Tax Code, financial indicator is the xxxxx, xxxx-up, xxxxx, operating or net profit margin which is analysed when applying the transfer pricing methods. According to part 1 of Article 364 of the Tax Code, the financial indicators are determined using the arm’s length principle to determine the profit tax base. Assume that in the scenario described abo...
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