Our purpose

Our tax audit services ensure compliance and defense for Armenia’s regulatory environment in 2025. Tailored for MNEs, we align with transfer pricing frameworks. We provide robust audit defense and regulatory negotiation, ensuring compliance and minimizing exposure. Our services protect positions and support MNE transfer pricing strategies.

Audit representation

Manages correspondence with tax inspectors

Represents clients in audit meetings

Maintains clear audit trail documentation

Supports MNEs through audit resolution

Technical defense file

Builds comprehensive tax defense files

Analyzes transactions, transfer pricing data

Aligns with OECD, local tax codes

Enhances MNE audit defensibility

Regulatory positioning

Develops arguments using OECD Guidelines

Addresses GAAR, substance challenges

Leverages double tax treaty protections

Aligns MNEs with regulatory expectations

Risk containment

Limits audit scope, overreach challenges

Negotiates settlements, staged disclosures

Manages financial, reputational exposure

Supports MNE risk minimization strategies

Who we advise

We serve clients for whom audit defense is a trust function:

Large enterprises: Facing full-scope audits.
Holding groups: Managing intercompany scrutiny.
Foreign investors: Resolving withholding disputes.
VAT claimants: Seeking refund approvals.
Financial groups: Addressing transfer pricing issues.
C-suite executives: Driving audit strategy.

Real-world impact: what our clients achieve

The challenge

Intense audit scrutiny risks

Weak documentation, defensibility

Complex regulatory demands

High penalty exposure

Our strategic response

Comprehensive defense files

Strategic regulatory arguments

Risk containment, negotiations

Transfer pricing-aligned solutions

Achieved results

Reduced tax liabilities, penalties

Faster audit resolutions

Full compliance, transparency

Aligned transfer pricing outcomes

Delivery models

Representation: Correspondence and audit meeting

Defense prep: Transaction analysis, documentation

Positioning: OECD-based arguments and treaties

Risk management: Scope limits, settlements

Why partner with us

Audit expertise

Deep OECD, IFRS knowledge.

Compliance assurance

Aligns with Armenian laws.

Proven methods

SAF-T, e-Audit systems.

Defense impact

Minimizes penalties, exposure.

Tailored solutions

Fits MNEs, industries.

FAQ

Frequently asked questions

Explore our frequently asked questions to learn more about TML’s features, security, integration capabilities, and more

What is tax audit representation?

It provides defense and negotiation during audits, ensuring compliance and minimizing exposure.

What does a defense file include?

It includes transaction analysis, transfer pricing, and OECD-aligned documentation for audits.

How do you position arguments?

We use OECD Guidelines, treaties, and local precedents to address regulatory challenges.

Can you support MNE audit strategies?

Yes, we align defenses with transfer pricing for global compliance and resolution.

What tools do you use for audits?

We leverage SAF-T, e-Audit trails, and dashboards for real-time audit management.

How do you contain audit risks?

We limit scope, negotiate settlements, and manage exposure to minimize penalties.

What deliverables do you provide?

We deliver defense files, position papers, settlement strategies, and audit reports.

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Tax audit representation