Armenia signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (CbC MCAA) on 5 September 2024, according to an OECD update.
Armenia’s CbC reporting starts on 1 January 2025 for MNE groups with consolidated revenue of over EUR 750 million, and reports are due 12 months after the fiscal year ends. Secondary local filing by non-parent entities in Armenia won’t be required.
Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a country-by-country (CbC) report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which they operate. This CbC report is shared with tax administrations in these jurisdictions, for use in high level transfer pricing and BEPS risk assessments.
105 jurisdictions have become signatories to the CbC MCAA, committing to the automatic exchange of CbC reports after Armenia’s signing.
