ARMENIA Trends and Developments Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC
Introduction The gaming industry in Armenia has long been a sec- tor of both opportunity and scrutiny. While the sec- tor attracts investment, generates employment, and contributes substantially to state revenues, it also raises public policy concerns regarding social impact, responsible gaming, and regulatory oversight. Over the past decade, the Armenian government has pro- gressively moved from a fragmented framework of fixed fees and limited exemptions to a comprehen- sive fiscal regime embedded within the Tax Code. This evolution seeks to balance the economic benefits of gaming with the need to mitigate potential social and financial harms associated with unregulated gambling. The broader objective of recent reforms has been to strengthen state oversight, ensure transparent and predictable taxation, and align domestic practice with international standards, including principles of income taxation, fiscal governance, and AML compliance. Between 2018 and 2025, Armenia enacted succes- sive legislative amendments that reshaped taxation in the sector. These reforms introduced a more nuanced treatment of player winnings, including the concept of “large winnings”, and revised state duties linked to the volume of accepted bets. For gaming activity organisers and potential entrants into Armenia’s gaming market, understanding the tra- jectory of these reforms is critical. The tax regime is no longer based on simple fixed fees or exemptions but increasingly aligns with international principles, promoting regulatory compliance, fiscal transparency, and responsible gaming practices. Evolution of Taxation in the Gaming Sector The taxation framework for Armenia’s gaming indus- try has undergone several stages of reform aimed at enhancing transparency, consistency, and fiscal effi- ciency. These reforms have affected both the treat- ment of player winnings and the taxation of gaming activity organisers, reflecting a shift from ad hoc or preferential mechanisms toward a unified and predict- able system. The gradual evolution demonstrates Armenia’s inten- tion to reduce regulatory arbitrage and align the taxa- tion of gaming with its broader fiscal policy objectives,
including enhancing public revenue collection and promoting a more responsible gaming environment. Taxation of Player Winnings Historical approach Prior to the introduction of Armenia’s Tax Code in 2018, the taxation of winnings depended on their source. Winnings from lotteries were considered exempt income for individuals. Casino winnings, by contrast, were not classified as exempt, yet the law did not require tax agents to with- hold income tax from such winnings. This approach created inconsistencies and limited tax collection efficiency. 2018–21: transitional framework From 1 January 2018 to 1 January 2021, the Tax Code established a transitional regime. During this period: • winnings from promotional lotteries were exempt up to a threshold of AMD50,000 per prize; • winnings from the monetary and in-kind winnings of participants in draw-based, non-draw, and com- bined lotteries, as well as totaliser (pool betting) games, were generally considered exempt; and • winnings from casinos, gaming, and internet gam- ing remained technically taxable, but tax agents were released from withholding taxes. The State thereby continued to exempt or simplify taxation of many forms of winnings, while gradually preparing for a more comprehensive system. 2021 onwards A significant reform took effect on 1 January 2021, extending the scope of deductible (non-taxable) income to include winnings from casinos, gaming, and internet gaming. This change effectively harmonised the tax treatment of all categories of player winnings under a unified exemption regime. Definition of “large winnings” In 2024, the reforms introduced the concept of a “large winning”, defined as a single win equal to or exceed-
27 CHAMBERS.COM
Powered by FlippingBook