Armenia opens a one-off cure window for missed VAT registration back to 2022

What changed in detail

Armenia’s Law No. HO-234-N, adopted on 6 May 2026 and officially published on 3 June 2026, adds Article 33(5) to the Tax Code creating a one-off cure window. A taxpayer who, in the cases specified by Article 59(1)(3), (5) and (2)(2), failed to submit the VAT-payer registration declaration and was not registered as a VAT payer may apply to the tax authority by 21 December 2026 inclusive for the opportunity to file that declaration; a taxpayer who files it by 31 December 2026 inclusive on the basis of an accepted application is registered as a VAT payer for the relevant case and deadlines. The provision applies to relationships arising from 1 January 2022, and VAT liabilities previously assessed on the ground of non-registration, including those under judicial appeal, are subject to recalculation. The provision took effect on 1 July 2026.

What it means

Two dates do two different jobs. 21 December is when the application for the opportunity must be filed; 31 December is the deadline to actually file the registration declaration once that application is accepted — miss either one and the cure window closes. The retroactive reach to 1 January 2022, combined with recalculation of VAT already assessed on non-registration grounds, including assessments still under judicial appeal, means a taxpayer mid-dispute over an old non-registration assessment may get a cleaner route to resolve it than continuing to litigate. This is a narrow, one-off amnesty tied to specific paragraphs of Article 59 — it does not excuse a failure to register going forward.