A/HRC/41/41/Add.4 100. The Special Rapporteur notes that while the possibility of having income-generating activities is a positive reform to the law on associations, it can also create burdensome duties in relation to separate accounting and taxation. Furthermore, he notes that the income from economic activities is taxed in the same way as companies. 101. Finally, the Special Rapporteur is concerned about proposed amendments to the law on NGOs that, if accepted, could introduce retrogressive changes to the reporting requirements of NGOs by adding unreasonable and disproportionate requirements for associations.11 B. Challenges and good practices 1. Civil society actors 102. Civil society is active and largely able to operate freely. Overall, the legal framework regulating the activities of associations is in compliance with international human rights standards, however the Special Rapporteur notes that challenges still persist. 103. For example, while the Special Rapporteur recognizes that the registration of NGOs is a fairly quick and simple process, he learned of the difficulties that civil society outside the capital has encountered in trying to register: the lack of clarity in the procedure; the discretionary interpretation by the local administration on whether proposed charter provisions are lawful or not; and unjustified delays in the procedure. 104. The Special Rapporteur notes the improvements made to the registration process, in particular with the “one-window registration process”. However he believes that an online service, or the possibility to register in the regional offices would provide not only a better service for those outside Yerevan but equal treatment in relation to private businesses which do have access to registration services throughout the country and enjoy an expedited registration process. 105. The Special Rapporteur notes that further training courses could be offered to the administration with a view to improving its expertise and client-orientation skills and avoiding discretionary interpretation by local authorities when approving the charters of civil society organizations. 106. The Special Rapporteur also believes that similar challenges exist in relation to the lack of knowledge and established procedures within the State Revenue Committee, but most importantly he questions whether tax inspection bodies are the most appropriate oversight authority for the non-profit sector owing to the lack of understanding of their goals and operations. He raised his concerns in meetings with representatives of the State Revenue Committee in relation to the public funding report forms approved in February 2018. He believes that such forms could be burdensome for NGOs who worry about the level of detail that needs to be provided and that is not strictly related to the source of funds, such as information on programmes, numbers of volunteers and number of board members. 107. The Special Rapporteur understands that the fight against money-laundering and corruption are legitimate interests in favour of transparency in the country and that reporting requirements facilitate accountability. However, he stresses that such a procedure should not be arbitrary and must respect the principle of non-discrimination and the right to privacy as it would otherwise put the independence of associations and the safety of their members at risk. 108. Other challenges remaining are the lack of guidelines on tax obligations related to earned income that can put NGOs at a disadvantage compared to business entities. Ambiguous provisions regarding procedures and obligations in relation to new concepts of social entrepreneurship and paid-for services were also raised as a problem during meetings with civil society representatives. 11 See www.e-draft.am/projects/1283. 13