- Law No. 9920/2008 “On Tax Procedures in the Republic of Albania” establishes the principle of self-assessment, meaning that the taxpayer declares and calculates his own liabilities.
- The Tax Administration's audit is not random but is based on risk analysis, according to criteria that the administration updates from time to time.
- For taxpayers who avoid filing or paying, the law provides graduated administrative measures, from fines to interest charges.
- Every taxpayer has the right to administrative appeal within 30 days to the Tax Appeals Directorate, but the assessed principal liability must be paid in advance.
- The law has been continuously amended since its adoption in May 2008, so the specific provisions should be verified in the current, effective text before relying on them.
Law No. 9920, dated May 19, 2008, “On Tax Procedures in the Republic of Albania,” as amended, is the act that regulates how tax obligations are administered in the country, how the Tax Administration is organized and functions, and what the rights and obligations of the taxpayer are. It is not the law that determines how much is paid, but the law that determines how it is declared, how it is audited, and how it is appealed.
In our daily work, we often see businesses that know the income tax or VAT law but don't know exactly how the procedure works afterward, what happens when an audit comes, or how to proceed when they disagree with an assessment by the tax authority.
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Basic Principles of Law No. 9920/2008
Self-assessment, the taxpayer's primary responsibility.
The Albanian tax system is based on the principle of self-assessment. This means that the taxpayer calculates, declares, and pays their obligations themselves, without waiting for the administration to issue a preliminary assessment. The Tax Administration, in balance with this principle, retains its supportive and supervisory role, but the primary responsibility for the accuracy of the declaration remains with the business.
Risk-based control, not random control.
The Tax Administration does not uniformly audit every taxpayer. The law ties the right to audit to risk analysis, that is, to criteria that identify cases with the highest probability of irregularity. This approach was significantly strengthened after sectoral risk management plans, such as that for the bar and restaurant sector, and remains the administration's standard practice today.
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 notificationsThe right to appeal
30-Day Period and the Tax Appeals Directorate
When a taxpayer disagrees with a notice of assessment or any other administrative act, the law grants them the right to administrative appeal to the Tax Appeals Directorate within 30 days from the date of the act. This right stems from Article 106 of Law No. 9920/2008, but since administrative procedures change from time to time, the exact deadline and precise steps must be verified in the current text of the law before being used in a specific case.
Rule of advance payment
In general, to appeal an assessed tax liability, that liability must be paid in advance, although fines and penalties are not necessarily included in this rule. If the Tax Appeals Directorate does not issue a decision within the prescribed deadline, or if its decision does not satisfy the taxpayer, the taxpayer may still pursue the matter in the competent court.
Why it Matters
Many businesses miss the appeal deadline.
The most common mistake is not the failure to recognize the right to appeal, but the missed 30-day deadline, often because the notice goes unnoticed by the administrator or accountant in time. Once the deadline passes, the opportunity for administrative appeal closes, leaving only the judicial route, which is longer and more expensive.
How we handle this with our clients
When a client receives a notice from the Tax Administration, we immediately assess whether there is grounds for an appeal, calculate the 30-day deadline ourselves, and notify the client in time to decide how to proceed.
Frequently asked questions
What does self-esteem mean in practice?
It means that you calculate and report your tax liabilities yourself, without waiting for a preliminary assessment from the administration. The administration then checks the accuracy of the return based on risk analysis.
Do I have to pay before I file a complaint?
As a general rule, yes, the principal assessed liability must be paid in advance for the appeal to be considered. Fines and specific cases may be handled differently, so we recommend checking the specific situation with a specialist before proceeding.
What happens if I miss the 30-day deadline?
After the deadline has passed, the opportunity for administrative appeal to the Tax Appeals Directorate closes. The route to the competent court remains open, but the process becomes longer and more costly.
Is this the only law that regulates tax procedures?
Law No. 9920/2008 is the primary act and remains in force, having been amended several times since its adoption in 2008. Alongside it, subsidiary acts and guidelines issued by the Ministry of Finance clarify its implementation in detail.
The full text and any amendments to the law are published on the official DPT website. Source: DPT page. Since the law changes from time to time, we recommend verifying the current text before relying on any specific provision.
