Armenian transfer pricing(TP)regulations are still in the starting period of their application,as the provisions for conducting TP administration have been put into force only since 13 April 2022.Prior to that,the TP ...Armenian transfer pricing(TP)regulations are still in the starting period of their application,as the provisions for conducting TP administration have been put into force only since 13 April 2022.Prior to that,the TP legislation was incomplete due to lack of provisions for effective tax administration.When the legislative amendments took effect,the TP became a separate type of tax audit with its specific features on procedure.Notwithstanding the fact that amendments solved many legislative issues,there were still many problems that emerged while applying the provisions in practice and hence needed to be tackled by further legislative amendments.This article explores some of the current major problems that the Armenian TP regulations face and the possible solutions that might be implemented in the near future.展开更多
This article analyzes the historical progression of tax administration in the utilization of computer technology since the mid-20th century.The digitalization of tax administration is divided into three main stages wh...This article analyzes the historical progression of tax administration in the utilization of computer technology since the mid-20th century.The digitalization of tax administration is divided into three main stages which are elaborated respectively.The most precise analysis is performed for today's practice with using of machine learning and artificial intelligence(ML&AI),and the key areas for ML&AI implementation in tax administration are identified.Some examples and results of applying ML&AI tools in Armenian Tax Administration are also presented.Plans for future activities in the area of digitalization are also presented.The article also tries to predict in which direction progress will go,what will be the most important change in Tax Officer vs.Taxpayer Cooperation.展开更多
The current transfer pricing(TP)legislation of Armenia was elaborated back in 2014-2015 and the Tax Code with a special TP chapter in it(Chapter 73)was adopted in 2016.The provisions of 2016 Tax Code came into force i...The current transfer pricing(TP)legislation of Armenia was elaborated back in 2014-2015 and the Tax Code with a special TP chapter in it(Chapter 73)was adopted in 2016.The provisions of 2016 Tax Code came into force in 2018,but the implementation of the TP regulations came into force on 1 January 2020.Currently,the legal framework of TP regulations is not complete for conducting tax administration.In this regard,in early 2021,a project on amending TP regulations was proposed,which has been already effective since 13 April 2022.This paper will discuss the five biggest issues of the current TP regulations and the proposed amendments and additions to the TP rules as solutions to those issues,which would help to effectively conduct tax administration.展开更多
文摘Armenian transfer pricing(TP)regulations are still in the starting period of their application,as the provisions for conducting TP administration have been put into force only since 13 April 2022.Prior to that,the TP legislation was incomplete due to lack of provisions for effective tax administration.When the legislative amendments took effect,the TP became a separate type of tax audit with its specific features on procedure.Notwithstanding the fact that amendments solved many legislative issues,there were still many problems that emerged while applying the provisions in practice and hence needed to be tackled by further legislative amendments.This article explores some of the current major problems that the Armenian TP regulations face and the possible solutions that might be implemented in the near future.
文摘This article analyzes the historical progression of tax administration in the utilization of computer technology since the mid-20th century.The digitalization of tax administration is divided into three main stages which are elaborated respectively.The most precise analysis is performed for today's practice with using of machine learning and artificial intelligence(ML&AI),and the key areas for ML&AI implementation in tax administration are identified.Some examples and results of applying ML&AI tools in Armenian Tax Administration are also presented.Plans for future activities in the area of digitalization are also presented.The article also tries to predict in which direction progress will go,what will be the most important change in Tax Officer vs.Taxpayer Cooperation.
文摘The current transfer pricing(TP)legislation of Armenia was elaborated back in 2014-2015 and the Tax Code with a special TP chapter in it(Chapter 73)was adopted in 2016.The provisions of 2016 Tax Code came into force in 2018,but the implementation of the TP regulations came into force on 1 January 2020.Currently,the legal framework of TP regulations is not complete for conducting tax administration.In this regard,in early 2021,a project on amending TP regulations was proposed,which has been already effective since 13 April 2022.This paper will discuss the five biggest issues of the current TP regulations and the proposed amendments and additions to the TP rules as solutions to those issues,which would help to effectively conduct tax administration.
