Më datën 23 prill 2026, Kuvendi i Republikës së Shqipërisë miratoi ligjin nr. 45/2026 On April 23, 2026, the Parliament of the Republic of Albania approved Law No. 45/2026 for the ratification of the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR). This law is closely linked to STTR conventions. The law was promulgated by Presidential Decree No. 315 on May 14, 2026, and enters into force 15 days after its publication in the Official Gazette.
The Convention is internationally recognized as the STTR instrument, an abbreviation for the Subject to Tax RuleIt was developed by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) and was approved in Paris on September 15, 2023.
Rregulli i ri prek një kategori të caktuar pagesash ndërkufitare brenda grupeve të lidhura të kompanive. Për shumicën e bizneseve të vogla shqiptare, ndikimi i drejtpërdrejtë është i kufizuar. Megjithatë, kompanitë me strukturë grupi ndërkombëtar duhet të kuptojnë në thellësi pasojat e këtij ligji.
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What is the Multilateral STTR Convention?
The Multilateral Convention is a technical instrument that simultaneously modifies existing double tax treaties between Albania and other signatories. Without this instrument, each bilateral treaty would need to be renegotiated individually—a process that would take decades.
The STTR is a treaty-based rule that allows the source country of income to impose an additional tax on specific payments between related parties. It applies when those payments are taxed in the recipient jurisdiction at an adjusted nominal rate below 9%.
The mechanism is simple in principle: if the effective tax rate at the recipient level is below 9%, the source country may apply a top-up tax to fill the gap up to the 9% threshold. The Convention covers seven categories of intra-group payments, the most significant of which are interest on internal loans and royalties for intellectual property.
Who is affected and who is not?
Typical clients of AlProfit Consult —small and medium-sized Albanian businesses operating domestically—are not affected by this rule. The Albanian corporate income tax regime of 0% for businesses with an annual turnover of up to 14,000,000 ALL remains unchanged until 2029.
The STTR Convention addresses the shifting of profits by multinational groups toward low-tax jurisdictions. Specifically, it affects:
- Albanian subsidiaries of multinational groups that receive or send intra-group payments;
- Albanian companies receiving interest, royalties, or service fees from related parties residing in jurisdictions with an adjusted nominal tax rate below 9%;
- Albanian companies sending such payments abroad to related parties in such jurisdictions.
A key difference from the Global Anti-Base Erosion (GloBE) Rules is that the STTR has no group turnover threshold. While GloBE applies only to groups with a turnover exceeding €750 million, the STTR applies regardless of size, provided the other applicability conditions are met.
Practical implications
Following the entry into force of the Convention and the deposit of notifications by other parties, Albania’s bilateral tax treaties will be supplemented with the STTR provision. Albanian tax authorities will have the legal basis to apply a withholding top-up tax on certain payments that historically benefited from lower treaty rates.
The Convention also provides a significant system of exclusions. Payments to independent individuals, recognized pension funds, religious, charitable, scientific, or educational non-profit organizations, central banks, and international organizations are not affected.
Article 9 of the Convention expressly provides that no reservations may be made regarding its provisions. However, each party may make notifications defining the scope of application within its individual treaties.
Why it Matters
Ratifying the STTR Convention is a concrete step that positions Albania within the OECD/G20 BEPS international framework. For foreign investors evaluating Albania as a jurisdiction, this serves as an indicator of the country’s integration into international fiscal transparency standards.
For multinational groups already operating in Albania, it is time to review intra-group payment structures. Existing internal loan, licensing, and service agreements should be analyzed to determine if they fall under the scope of the STTR. Proactive reorganization can prevent tax surprises in future years.
Every time there is a tax or financial change that affects your business, we notify you directly by email with a practical explanation.
Send me free notificationsFrequently asked questions
Does Law No. 45/2026 affect my small business?
If your business operates solely within Albania and has no owners, subsidiaries, or related companies abroad, the law brings no practical changes. The 0% corporate income tax regime for businesses with an annual turnover under 14,000,000 ALL remains unchanged until 2029.
When does the Convention practically apply?
Entry into force depends on the number of parties that ratify and deposit their instruments of ratification with the Depositary, according to Article 11 of the Convention. Each bilateral treaty is modified according to the timelines stipulated within the Convention itself.
What is considered a "related party" under the STTR?
The definition is technical and based on OECD standards. Generally, it includes companies within the same group, as well as persons owning directly or indirectly over 50% of each other's capital, and entities under common control.
Which payments are covered by the rule?
The Convention covers seven categories of intra-group income. The most prominent are interest, royalties for intellectual property, and certain service fees between related parties. The full list is provided in Annex I of the Convention.
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Read also 0% Corporate tax until 2029 for businesses with turnover under 14 million ALL.