Estonian Company Run from Armenia: Tax Rules

Many people living in Armenia form or buy an Estonian private limited company (OÜ), often as e-residents, and run it from Armenia. The Armenian Tax Code decides a company's residence by where it is registered, not by where it is managed: a company registered in Estonia is not an Armenian resident organisation. It can still have a permanent establishment in Armenia. On the owner side, an Armenian resident is taxed on income received outside Armenia, with a credit for foreign tax. And the Estonia–Armenia tax treaty leaves a company resident in both countries to the two tax authorities. This guide sets out these rules with the official texts, and what we do on the Estonian side.

The guide is general information, not tax advice. How your company and you are taxed depends on the facts of your case; ask an Armenian tax adviser before you form or buy the company. We read the Tax Code of the Republic of Armenia in its official incorporated Armenian text on arlis.am, the official legal information system, together with its official English translation there, and the Estonia–Armenia tax treaty in Riigi Teataja, on 22 October 2026. The Armenian text is the law.

In Estonia: an Estonian company is Estonian

A company established under Estonian law is resident in Estonia for tax purposes (Income Tax Act § 6). Its profit is taxed when it is distributed, not while it stays in the company — the guide how Estonia taxes company profit explains the rule. The company keeps its Estonian duties wherever its owners live: accounts, an annual report to the commercial register and, if its address is abroad, a contact person in Estonia.

In Armenia: the company side

Residence by registration. A resident organisation is an organisation located in Armenia (Tax Code, Article 22), and the location of an organisation is the place of its state registration (Article 23). An OÜ is registered in Estonia, so under these articles it is a non-resident organisation for Armenia.
Permanent establishment. A non-resident organisation can have a permanent establishment in Armenia — one of the places of business in Armenia listed in the Code, such as any place of management or a branch office, through which it conducts entrepreneurial activity (Article 27).
The rate. Profit tax is 18 percent, for resident profit taxpayers and for non-residents on the income attributed to a permanent establishment in Armenia (Article 125(1)).

Whether your work in Armenia for the company creates a permanent establishment there is a question for your Armenian tax adviser. The Tax Code has no rule that turns a foreign company into an Armenian one because it is managed from Armenia, and no controlled foreign company rule; we found neither in the text we read.

In Armenia: the owner side

Resident. A natural person is resident when actually present in Armenia for 183 or more days in the tax year; a person whose centre of vital interests — family and economic interests — is in Armenia is resident too (Article 25(1) and (3)).
Income from abroad. Income received outside Armenia by a resident is taxed in Armenia, and the tax is reduced by the corresponding tax collected abroad (Article 20(1) and (2)).
Dividends. Income tax on dividends is calculated at a rate of five percent (Article 150(8)).

How a dividend from the Estonian company is taxed in your hands in Armenia, and how the treaty credit works, is a question for your Armenian tax adviser.

The Estonia–Armenia tax treaty

A company resident in both countries. The competent authorities of the two countries decide by mutual agreement how the treaty applies to it (Agreement signed on 13 April 2001, in force since 23 January 2003, Article 4(3)).
Permanent establishment. A permanent establishment is a fixed place through which the business is wholly or partly carried on, and includes especially a place of management (Article 5).
Dividends. The country of the paying company may tax dividends at no more than 5 per cent of the gross amount when the recipient is a company directly holding at least 25 per cent of the capital, and 15 per cent in all other cases (Article 10(2)).
Directors' fees. Fees for a member of the board of a company resident in the other country may be taxed in that country (Article 16).

Under the Armenian articles an OÜ registered in Estonia is not an Armenian resident, so the treaty's tie-breaker is seldom needed. The treaty does not stop Armenia from taxing the profits of a permanent establishment in Armenia. We do not give that ruling.

What to decide before you form or buy the company

Where the business is done. A place of business in Armenia, such as a place of management, can be a permanent establishment.
Where you live. 183 days in Armenia, or your centre of vital interests there, makes you resident under Article 25.
How you take money out. A dividend and a board fee fall under different articles of the treaty.

What we do on the Estonian side

online formation for an e-resident — €950 Registered address and contact person service for one year are included., or formation by power of attorney — €1,250;
a ready-made company bought remotely — €1,200 Registered address and contact person service for one year are included.;
accounting — from €150 / month and the annual report — from €450;
the registered address and contact person after the first 12 months — €350 / year.

Our accounting covers the Estonian company's Estonian obligations. Armenian tax returns and Armenian tax advice are not included. Owners in other countries: Estonian company run from abroad compares the rules side by side.

Prices exclude VAT. All communication takes place by email.

Ready to start? A new Estonian company — online for e-residents or by power of attorney; Armenian tax advice is not included. Order.

Official sources

The laws this article names, by the name of their official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Income Tax Act — Riigi Teataja, English translation

Sources are named in the text, without links. To see which of our services your company needs, open the Business Navigator.

Frequently asked questions

Is my Estonian company taxed in Armenia if I run it from Armenia?

It can be, through a permanent establishment. Armenia decides a company's residence by its place of state registration, so an OÜ registered in Estonia is not an Armenian resident organisation (Tax Code, Articles 22 and 23); but a place of business in Armenia, such as any place of management, can be a permanent establishment whose profit is taxed in Armenia (Articles 27 and 125). In Estonia the company stays resident because it was established under Estonian law (Income Tax Act § 6). An Armenian resident — 183 days in Armenia or the centre of vital interests there — is taxed on income received abroad, with a credit for foreign tax (Articles 25 and 20). Ask an Armenian tax adviser before you form or buy the company; we handle the Estonian side.

Estonian company run from Armenia: what is taxed where