- The 2019 tax package introduced several amendments to Law No. 9920/2008 “On Tax Procedures” that still guide practice, such as a single NIPT for each individual, payment of obligations before transitioning to passive status, and electronic notifications.
- The tax administration was granted the right to use alternative valuation methods against individuals who hold more than one NIPT to avoid obligations.
- During the appeal or complaint process, interest ceases to be mandatory, and the penalty for invoice non-compliance is reduced by 30% when the taxpayer accepts and pays the assessment.
- Law No. 9920/2008 has undergone further amendments since 2019, including Law No. 79/2025. For each specific case, the current rule is verified in advance.
The 2019 fiscal package introduced a set of significant changes to Law No. 9920 of May 19, 2008 “On Tax Procedures in the Republic of Albania,” as amended. The changes affect taxpayer identification, passive status, notification methods, appeals, and certain specific fines.
From our daily work, we often see that businesses only remember the change that directly affected them once, and they forget the rest of the package, which can come up again at another time—such as in the case of deregistration, passive status, or an audit.
Read also: Expected tax law changes for 2026.
Taxpayer identification, one NIPT per natural person
The sole NIPT rule
A natural person with the same personal identification number is registered only once with the National Business Center. The right to obtain a new NIPT arises only after the complete deregistration of the existing NIPT, not concurrently with it.
Certificate of New Activity
When a sole proprietor registers a new business activity, they are issued a certificate bearing the same unique identification number as the original registration but with a different serial number, so that the specific location of the new activity can be identified.
Passive status and transactions with passive entities
The requirement to switch to passive in the QKB
The taxpayer seeking to switch to passive status with the QKB must have previously paid all tax obligations. Passive status cannot be used as a means to leave unpaid obligations behind.
Penalties for transactions with non-taxable entities
The law provides penalties for both the seller and the buyer when they conduct transactions with a party that is in “Passive” status. Therefore, verifying the other party's status is not merely a formality.
Alternative assessment methods versus the artificial segmentation of activity
The tax administration was granted the right to use alternative valuation methods and to issue an assessment of liability when a natural person engaged in trade holds more than one identification number and files separate returns for each NIPT in order to evade taxes or minimize liability. This closes one of the most common avenues for artificially splitting turnover among multiple NIPT numbers of the same individual.
- A natural person with several active NIPT accounts, each with a separate declaration.
- the apparent goal of minimizing total liability through division
- The administration issues a consolidated assessment, not for each NIPT separately.
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 notificationsElectronic notices and appeal without interest charges
Notice and request for payment by electronic means
Since this package, the notice and request for payment can be sent to the taxpayer electronically, not only by mail or hand delivery. This makes the accuracy of the contacts registered in e-Filing more important than ever.
Suspension of interest during appeal
During the appeal or complaint period, payment of late interest is no longer mandatory. A taxpayer who appeals a decision does not accrue late interest solely because the matter is still under review.
Fines for changing ownership without notification
A legal entity that fails to notify the tax administration of ownership changes faces fines tied to the market value:
- 15% of the market value of assets treated as a change of ownership
- 51 TP3T of the market value of shares or similar interests that have changed ownership.
Fine for inaccurate declaration and facilitation of invoices
Downward revaluation of the credit surplus
An incorrect declaration is also deemed to occur when, as a result of a tax audit, the taxpayer's credit surplus is reassessed downward. In this case, a penalty of 20% of the difference between the declared credit surplus and the amount that should have been declared is applied.
Reduction of the 30% fine for invoice violations
In cases of violations in the issuance of tax invoices, tax receipts, or the documentation of transactions, the fine is reduced by 30% if the taxpayer accepts the tax assessment and pays the liability instead of contesting it.
Fine limit for banks
The amount of the fine imposed on a bank when it fails to freeze a taxpayer's account at the request of the tax administration may not exceed the amount itself that was requested to be frozen.
Why it Matters
Most of these rules only take effect at specific moments—such as deregistration, moving to a passive status, or an audit—so we often encounter them as a surprise, precisely when the business is least prepared to handle them.
The law continues to change.
Law No. 9920/2008 has undergone further changes since 2019. A concrete example, verified by us, is Law No. 79/2025, which shortened the self-correction period for statements from 36 to 24 months. This shows why the rules presented here require additional verification for each specific case.
How we handle this with our clients
Before any action with potential consequences, such as deregistration, conversion to passive status, or acceptance of an assessment, we verify the current rule in effect rather than relying on the version of the law from a specific year.
Frequently asked questions
Can I have two active NIPT at the same time?
Not as a natural person with the same personal identification number. You must deregister the existing NIPT before obtaining a new one.
Can I go passive with unpaid obligations?
No. Switching to passive status with the QKB requires that all tax obligations have been paid in advance.
Do I still have to pay late fees when I appeal a decision?
No, as of this package, interest charges are no longer mandatory during the appeal or complaint period.
Do all these rules still apply unchanged today?
The principle applies, but Law No. 9920/2008 has undergone further changes since 2019. For a specific case, we recommend conducting a preliminary verification before taking action.
The changes presented here reflect the 2019 fiscal package, as announced at the time by the DPT. Official DPT Announcement. For subsequent amendments to the same law, see also our page on correction of tax returns.
