On 20 August 2026, the State Revenue Committee’s Training Centre announced a one‑day workshop scheduled for 27 August 2026 in Yerevan, focusing on “Practical Examples of Transfer‑Pricing Compliance Analysis for Service Transactions and Cross‑Border Payments”. The event will take place at the Committee’s headquarters on Aharonyan Street 12/3 and will provide attendees with a certificate of participation. The workshop aims to equip tax advisors, multinational finance teams, and revenue officers with concrete methodologies for assessing arm’s‑length pricing in intra‑group services, royalties, and technical‑fee arrangements, reflecting the growing importance of the services sector in Armenia’s export base.
Key Takeaways
- Service‑Specific Transfer Pricing Guidance: The workshop will address the unique challenges of pricing intangible services, including management fees, IT support, and marketing assistance, where comparable uncontrolled prices are often scarce. Participants will learn how to apply profit‑split and transactional net‑margin methods, and how to document functional analyses that justify the chosen approach.
- Emphasis on Documentation and Contemporaneous Evidence: In line with OECD BEPS Action 13 recommendations, the training will stress the need for master files, local files, and country‑by‑country reports that are prepared contemporaneously with the tax year. Proper documentation reduces the risk of adjustments during audits and facilitates advance pricing agreements (APAs).
- Practical Case Studies from Armenian Context: Real‑world examples drawn from recent SRC audits will illustrate common pitfalls, such as misclassification of service royalties as technical fees, and incorrect allocation of overhead costs. Attendees will work through these cases to develop robust defence strategies and settlement positions.
Disclaimer:This article is compiled and summarized based on publicly available information and is for general information and academic exchange purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. For tax planning, please consult a qualified professional tax advisor or legal counsel.
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