The treaty generally applies from 1 January 2026. However, provisions of articles 25 (Exchange of Information) and 26 (Assistance in the Collection of Taxes) will enter into force from 20 December 2025, without regard to the date on which the taxes are levied or the taxable year to which the taxes relate.
The rates of withholding tax provided by DTT are:
Dividends
in general, the rate should not exceed 5% (in cases where the applicable rate in the country is higher), provided that the recipient of the dividends is the beneficial owner of that income
0% if the beneficial owner is a company which has owned directly or indirectly, throughout a 365-day period that includes the date on which entitlement to the dividends is determined, at least 25% of:the capital of that company (for cases where the company paying the dividends is a resident of Armenia);
1. the voting power of that company (for cases where the company paying the dividends is a resident of Japan);
2. the rate should not exceed 10% (in cases where the applicable rate in the country is higher) if the dividends paid by a company are deductible in computing its taxable income, provided that the recipient of the dividends is the beneficial owner of that income
Interest
in general the rate should not exceed 5% (in cases where the applicable rate in the country is higher), provided that the recipient of the interests is the beneficial owner of that income;
0% if the interest is beneficially owned by:
1. the other contracting state, a political subdivision or local authority thereof, the central bank or any institution wholly owned by that other contracting state or a political subdivision or local authority thereof; or
2. a resident of the other contracting state with respect to debt-claims guaranteed, insured or indirectly financed by that other contracting state, a political subdivision or local authority thereof, the central bank or any institution wholly owned by that other contracting state or a political subdivision or local authority thereof;
Royalties
5% if the beneficial owner of the royalties is a resident of the other contracting state.
Details of the treaty are available in the file attached:
