Gaming Law 2025

ARMENIA Trends and Developments Contributed by: Roustam Badasyan, Artur Manukyan, Marianna Grigoryan and Davit Baklachyan, Badasyan Consulting LLC

Prior to 2020, licensing fees were geographically dif- ferentiated. For example, casinos in Yerevan faced much higher fees than those in resort towns such as Tsakhkadzor, Sevan, or Jermuk. Fees ranged from AMD30 million (EUR67,172) in smaller towns to AMD4.5 billion (EUR10,075,905) in other locations. Lottery and internet gaming licences were subject to annual fees of AMD500 million (EUR1,119,545). As part of the 2020 reform, fees were increased under the Law on State Duty. Key provisions include: • lotteries – AMD600 million annually (EUR1,343,454).; • casinos ‒ annual duties vary by location, for exam- ple: (a) Tsakhkadzor ‒ AMD180 million (EUR403,036); (b) Sevan ‒ AMD150 million (EUR335,863); (c) Jermuk ‒ AMD100 million (EUR223,909); (d) Meghri ‒ AMD35 million (EUR78,368); and (e) other locations ‒ AMD5.5 billion (EUR12,314,995); and • internet gaming ‒ AMD600 million annually (EUR1,343,454). As part of the 2023 reform, a novel approach was introduced from 1 July 2023 for online gaming and totaliser operators. Instead of only paying annual licensing fees, operators are now required to pay state duty based on the volume of bets accepted: • AMD175 million (EUR391,840) for every AMD100 billion (EUR223,909,003) in accepted internet gam- ing bets; and • AMD50 million (EUR111,954) for every AMD50 bil- lion (EUR111,954,501) in accepted totaliser bets. As part of the 2024 reform, recent amendments – adopted on 12 June 2024 ‒ introduced an annual licensing fee for bookmaker activities in the amount of AMD600 million (EUR1,343,454). The 2024 reforms also introduced coefficients for duties linked to accepting bets. The legislation established a phased approach to effect these coefficients. For the pur- poses of calculating the state duty, the applicable multiplier shall be: • 2.0 from 1 April 2025;

• 3.0 from 1 January 2026; • 4.0 from 1 January 2027; and • 5.0 from 1 January 2028.

This progressive increase is intended to substantially raise the fiscal burden on operators over time, there- by both regulating the sector and ensuring significant contributions to the state budget. Recent Developments and Policy Trends Several themes have emerged from Armenia’s recent trajectory in gaming taxation. Rising fiscal burden Successive reforms have increased both the duties payable by gaming organisers and the effective taxa- tion of players’ winnings. Alignment with income taxation principles By bringing winnings and organiser income fully into the scope of the Tax Code, Armenia has reduced reli- ance on fixed fees and exemptions. Shift towards online regulation The 2023 duty reform reflects the increasing domi- nance of online gaming and betting. Policy rationale The government has framed these reforms as both a revenue-raising measure and a tool to promote responsible gaming by limiting excessive participa- tion through higher costs. Key Considerations for Clients For clients, the following considerations are particu- larly important. Compliance costs are increasing Entry into the Armenian market requires careful finan- cial planning to accommodate state duties, corporate taxation, and compliance with reporting obligations. Unlicensed operations are penalised Players face a 20% tax rate on winnings from unli- censed operators, which may discourage use of off- shore or informal platforms.

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