Armenia holds EAEU marketplace operators liable for VAT on goods sold to Armenian consumers

What changed in detail

Armenia’s Law No. ՀՕ-83-Ն, adopted 4 March 2026, signed 30 March and officially published 31 March 2026, adds a new part 3 to Article 70 of the Tax Code — article 10 of the amending law reads “Օրենսգրքի 70-րդ հոդվածում … լրացնել հետևյալ բովանդակությամբ 3-րդ մասով” (“in Article 70 of the Code … supplement with the following part 3”). Article 37 is amended separately, by article 3 of the same law, and is referred to inside the new part 3 only as the place-of-supply test. It makes an EAEU-member-state organisation or individual entrepreneur that operates an e-commerce platform liable to calculate and pay Armenian VAT on goods it supplies through that platform to Armenian natural persons — provided the seller is another EAEU-member organisation or entrepreneur with no permanent establishment in Armenia, and the buyer is not itself an individual entrepreneur or notary.

The liability applies irrespective of the VAT threshold — the platform operator does not get the benefit of Armenia’s ordinary small-seller VAT relief. The law enters into force 1 January 2027, with one narrow exception: a single implementing-regulation clause takes effect 10 days after publication.

This is the goods limb of platform VAT liability — a separate, earlier framework already covers EAEU platforms supplying digital services to Armenian consumers.

What it means

The threshold carve-out is the detail most likely to be missed: a marketplace that would otherwise fall under a small-seller exemption does not get one here, because the law removes the threshold test entirely for this category of supply. EAEU-based marketplaces selling physical goods to Armenian consumers — rather than operating through an Armenian-established seller — have until 1 January 2027 to build VAT calculation, collection and remittance into their checkout flow for the Armenian market, regardless of sales volume.