On September 25, 2023, the Republic of Armenia submitted to the depositary of the Organization for Economic Cooperation and Development the documents pertaining to the 'Multilateral Convention on the Implementation of Measures Related to Tax Treaties to Prevent Distortion of the Tax Base and Profit Shifting' (hereinafter referred to as the Convention) and the accompanying list of reservations, which constitutes an integral part of the Convention. The Convention had been ratified by the RA National Assembly in September 2022.
The Convention will come into effect for the Republic of Armenia on January 1, 2024.
The text of the convention can be found at this link: [https://www.oecd.org/tax/treaties/multilateral-convention-to-implement-tax-treaty-related-measures-to-prevent-BEPS.pdf] and the reservations, which are an integral part of it, are available here: [https://www.oecd.org/tax/treaties/beps-mli-position-armenia-instrument-deposit.pdf].
The provisions of the Convention modify certain clauses in the bilateral agreements concluded between signatory States to prevent double taxation. However, these modifications only apply when both States have opted for the same approach to the application of a specific provision in the Convention, as outlined in the instrument of reservations to the Convention.
Information regarding the application of the Convention's provisions related to amending bilateral agreements on the avoidance of double taxation between the Republic of Armenia and other countries, specifically information on the alignment of choices made by the Republic of Armenia and other signatory states to the Convention for amending provisions in bilateral agreements, can be found at the following link: [https://www.oecd.org/tax/treaties/mli-matching-database.htm].