Armenia to triple criminal liability threshold for tax crimes - draft law
14.04.2026,
14:49
Armenia is proposing to triple the criminal liability threshold for tax crimes.
YEREVAN, April 14. /ARKA/. Armenia is proposing to triple the criminal liability threshold for tax crimes. The corresponding draft amendments to the Tax Code and several related laws were presented in the first reading by Eduard Hakobyan, head of the State Revenue Committee (SRC), at a parliamentary session on Tuesday.
According to him, the amendments to the Criminal Code provide for raising the current thresholds: currently, a large amount of unpaid taxes is defined as 10 million drams, and an especially large amount is defined as 20 million drams.
According to Hakobyan, the draft law proposes raising the large amount threshold to 30 million drams, and for liabilities for the following two years, to 45 million drams. The especially large amount threshold is proposed to be increased to 25-50 million drams, and for liabilities for the following two years, to 75 million drams.
The head of the State Revenue Committee stated that this will allow a significant portion of such cases to be transferred to the administrative level (decriminalized) and will mitigate criminal penalties in some cases.
Furthermore, the bill proposes changes to the SRC's procedures upon receiving information about a suspected tax crime. According to Hakobyan, the committee should not immediately file a report of the crime, but should first process the data using internal analytical tools, notify the taxpayer, and attempt to obtain a reasoned explanation.
If such an explanation is not provided, the tax authority will be able to record the violation as part of a thematic audit and draw up an administrative act, which can be appealed in accordance with established procedures. After this, the SRC will decide whether to file a report of the crime.
However, Hakobyan emphasized that exceptions will be made in cases where immediate action is required to prevent the loss of facts and evidence.
Another change concerns thematic audits. According to the head of the State Revenue Committee, it is proposed to exclude provisions regarding "known transactions" from their regulations, as well as lift the restriction on conducting such audits only once per tax year.
Akopyan stated that of the approximately 600 preliminary calculations per year, at least half could be transferred to administrative proceedings.
The bill also provides an alternative mechanism for cases of property seizure in criminal proceedings. It is proposed that, by decision of the investigator, the court, or with the consent of the supervising prosecutor, the seizure of property could be lifted upon the provision of a bank guarantee equal to its value.
According to him, the amendments to the Criminal Code provide for raising the current thresholds: currently, a large amount of unpaid taxes is defined as 10 million drams, and an especially large amount is defined as 20 million drams.
According to Hakobyan, the draft law proposes raising the large amount threshold to 30 million drams, and for liabilities for the following two years, to 45 million drams. The especially large amount threshold is proposed to be increased to 25-50 million drams, and for liabilities for the following two years, to 75 million drams.
The head of the State Revenue Committee stated that this will allow a significant portion of such cases to be transferred to the administrative level (decriminalized) and will mitigate criminal penalties in some cases.
Furthermore, the bill proposes changes to the SRC's procedures upon receiving information about a suspected tax crime. According to Hakobyan, the committee should not immediately file a report of the crime, but should first process the data using internal analytical tools, notify the taxpayer, and attempt to obtain a reasoned explanation.
If such an explanation is not provided, the tax authority will be able to record the violation as part of a thematic audit and draw up an administrative act, which can be appealed in accordance with established procedures. After this, the SRC will decide whether to file a report of the crime.
However, Hakobyan emphasized that exceptions will be made in cases where immediate action is required to prevent the loss of facts and evidence.
Another change concerns thematic audits. According to the head of the State Revenue Committee, it is proposed to exclude provisions regarding "known transactions" from their regulations, as well as lift the restriction on conducting such audits only once per tax year.
Akopyan stated that of the approximately 600 preliminary calculations per year, at least half could be transferred to administrative proceedings.
The bill also provides an alternative mechanism for cases of property seizure in criminal proceedings. It is proposed that, by decision of the investigator, the court, or with the consent of the supervising prosecutor, the seizure of property could be lifted upon the provision of a bank guarantee equal to its value.
