On 28 July 2026, Armenia enacted Law HO-385-N amending the Tax Code of the Republic of Armenia and introducing a special tax regime for dividends distributed by banks. Under the new rules, dividends derived from non-listed shares of banks, as well as participation in a bank’s share or equity capital, will be subject to a 15% tax rate. The amendments apply to both corporate and individual recipients and establish new withholding and reporting obligations for banks acting as tax agents. The rules also extend to certain shareholders holding more than 1% of a bank’s listed shares.
These changes represent a departure from the previously applicable tax treatment of dividends, under which dividends paid to resident corporate shareholders were generally exempt from tax, while dividends paid to individuals and non-resident corporate shareholders were generally subject to tax at a 5% rate. The new regime is intended to increase the taxation of income derived from investments in the banking sector.
The amendments generally enter into force on 1 February 2027 and will also apply to dividends distributed from profits relating to periods before 1 January 2027. It should be noted, however, that a substantially similar regime has already applied since 30 July 2026 with the introduction of a state duty on such dividend distributions under comparable conditions. This transitional state duty regime will remain in force until 31 December 2026, after which it will be replaced by the new tax rules set out in the Tax Code.