Albania

Corporate - Withholding taxes

Last reviewed - 22 June 2020

The gross amount of interest and royalties paid to non-resident companies is subject to a 15% tax rate, while dividends and distribution of profits are taxed at a rate of 8%, unless a DTT provides a different rate.

The 15% tax rate is levied on the gross amount of payments for technical, management, installation, assembly, or supervisory work, as well as payments to management and board members.

If a non-resident company does not create a PE in Albania, and a DTT exists between Albania and the home country of the non-resident company, no WHT payment may arise.

Double tax treaties (DTTs)

Albania has signed 43 DTTs, of which 39 are in force. 

WHT rates envisaged by applicable DTTs are provided in the following table:

Recipient WHT (%) Applicable from
Dividends Interest Royalties
Non-treaty 8 15 15  
Treaty:        
Austria 5/8 (6) 5 5 1/1/2009
Belgium 5/8 (6) 5 5 1/1/2005
Bosnia and Herzegovina 5/8 (5) 10 10 1/1/2009
Bulgaria 5/8 (6) 10 10 1/1/2000
China 8 10 10 1/1/2006
Croatia 8 10 10 1/1/1999
Czech Republic 5/8 (6) 5 10 1/1/1997
Egypt 8 10 10 1/1/2006
Estonia 5/8(5) 5 5 1/1/2018
France 5/8 (6) 10 5 1/1/2006
Germany 5/8 (6) 5 5 1/1/2012
Greece 5 5 5 1/1/2001
Hungary 5/8 (5) N/A 5 1/1/1996
Iceland 5/8 (5) 10 10 1/1/2017
India 8 10 10 -
Ireland 5/8 (5) 7 7 1/1/2012
Italy 8 5 5 1/1/2000
Korea 5/8 (5) 10 10 1/1/2009
Kosovo 8 10 10 1/1/2006
Kuwait 0/5/8 (3) 10 10 1/1/2014
Latvia 5/8 (5) 5/10 (2) 5 1/1/2009
Luxembourg 5/8 (5) 5 5 -
Macedonia 8 10 10 1/1/1999
Malaysia 5/8 (6) 10 10 1/1/1995
Malta 5/8 (6) 5 5 1/1/2001
Moldova 5/8 (5) 5 10 1/1/2004
Morocco 8 10 10 -
Netherlands 0/5/8 (1) 5/10 (2) 10 1/1/2006
Norway 5/8 (6) 10 10 1/1/2000
Poland 5/8 (5) 10 5 1/1/1995
Qatar 5 5 6 3/5/2012
Romania 8 (7) 10 15 1/1/1995
Russia 8 10 10 1/1/1998
Saudi Arabia 5 6 5/8 (9) -
Serbia and Montenegro 5/8 (6) 10 10 1/1/2006
Singapore 5 5 5 1/1/2012
Slovenia 5/8 (5) 7 7 1/1/2010
Spain 0/5/8 (4) 6 0 4/5/2011
Sweden 5/8 (6) 5 5 1/1/2000
Switzerland 5/8 (6) 5 5 1/1/2001
Turkey 5/8 (6) 10 10 1/1/1997
United Arab Emirates 0/5/8 (3) N/A 5 1/1/2014
United Kingdom 5/8 (8) 6 N/A 1/1/2014

Notes

  1. If the recipient company directly or indirectly owns 50% of the capital of the paying company, a 0% rate of the gross amount of the dividends applies. If the recipient company directly or indirectly owns 25% of the capital of the paying company, a 5% rate of the gross amount of the dividends applies. A tax rate of 8% of the gross amount of the dividends applies in all other cases.
  2. A tax rate of 5% of the gross amount of the interests applies in case of interests in a contracting state, which are paid to a loan granted by a bank or any other financial institution of the other contracting state, including investment banks and savings banks and insurance. A tax rate of 10% of the gross amount of the interests applies in all other cases.
  3. If the recipient company or any other governmental body is a resident of the other contracting state, a 0% rate of the gross amount of the dividend applies. If the recipient company (other than a partnership) directly or indirectly owns at least 10% of the capital of the paying company, a 5% rate of the gross amount of the dividends applies. A tax rate of 8% of the gross amount of the dividends applies in all other cases.
  4. If the recipient company (other than a partnership) directly or indirectly owns at least 75% of the capital of the paying company, a 0% rate of the gross amount of the dividends applies. If the recipient company (other than a partnership) directly or indirectly owns at least 10% of the capital of the paying company, a 5% rate of the gross amount of the dividends applies. A tax rate of 8% of the gross amount of the dividends applies in all other cases.
  5. If the recipient company (other than a partnership) directly or indirectly owns at least 25% of the capital of the paying company, a 5% rate of the gross amount of the dividends applies. A tax rate of 8% of the gross amount of the dividends applies in all other cases.
  6. If the recipient company (other than a partnership) directly or indirectly owns at least 25% of the capital of the paying company, a 5% rate of the gross amount of the dividends applies. A tax rate of 8% of the gross amount of the dividends applies in all other cases.
  7. If the recipient company (other than a partnership) directly or indirectly owns at least 25% of the capital of the paying company, a 10% rate of the gross amount of the dividends applies. A tax rate of 8% of the gross amount of the dividends applies in all other cases.
  8. If the recipient company (other than a partnership) directly or indirectly owns at least 25% of the capital of the paying company or is a pension scheme, a 5% rate of the gross amount of the dividends applies. The tax rate switches to 15% of the gross amount of the dividends where those dividends are paid out of income (including gains) derived directly or indirectly from immovable property by an investment vehicle that distributes most of this income annually and whose income from such immovable property is exempted from tax. A tax rate of 8% of the gross amount of the dividends is applied in all other cases.
  9. 5% for royalties that are paid for the use of, or the right to use, industrial, commercial, or scientific equipment, and 8% in all other cases.