Enforcement by force only begins once the obligation is final, that is, after the appeals process has been exhausted. The measures follow a sequence: notice and demand for payment, freezing of bank accounts, security or mortgage lien, seizure, confiscation, and auction. These measures also include the blocking of a bank account by the tax authorities. At each stage, there is the right to appeal within 30 days.
This page explains each measure, its own deadline, and what can be done in the meantime. The best approach remains an installment payment agreement before the procedure begins, because once it starts the window narrows and costs increase.
Read also: Tax audit, fines, and appeal of the assessment.
The tax administration exercises its powers of coercive collection only after the right of appeal has been exhausted, in accordance with Article 88 of Law No. 9920/2008. Therefore, a liability that is under appeal, filed within the deadline and secured by payment or a bank guarantee, does not follow this procedure.
The first step is the notice and demand for payment under Section 89. This notice is the point at which the matter can be put on hold with an installment agreement, and in our practice it is also the point most often missed, because the notice is not read in time.
Article 89 also provides for two measures that depart from the ordinary procedure. The first is on-site monitoring of operations, with daily confiscation of a portion of turnover not less than 50%. The second, under Article 89(4)(a), is the requirement to prohibit the administrator, partner, or shareholder from leaving the country, which applies only in cases of risk.
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| Mass | Term or condition | Article |
|---|---|---|
| Notice and Demand for Payment | The first step, after the exhaustion of appeal | 89 |
| On-site monitoring, daily confiscation of no less than 50% of turnover. | According to the administration's decision | 89 |
| Request for a travel ban outside the country | Only in case of emergency | Eighty-nine point four A |
| Freezing of bank accounts | By order of the administration | 90 |
| Insurance and mortgage lien | With prior notice | 91 |
| Seizure of property | 30 days after the order, or immediately when the collection is at risk. | 93 |
| Confiscation and auction | Auction within 15 days; surplus returned within 5 business days. | 96 |
| Third-party transfer | Payment within 14 days | 97 |
| Direct request to the third party | thirty days | 98 |
| Appeal of the measure | thirty days | 92 |
The freezing of bank accounts is the first enforcement measure and is carried out by order of the tax administration under Article 90. The bank executes the order, so any discussion regarding the lifting of the freeze should be conducted with the tax administration, not with the bank.
In practice, a blockage halts supplier payments, wages, and contributions, creating new obligations on the existing debt. Therefore, the priority is not filing a complaint with the bank but settling the debt or lodging an appeal within 30 days.
Attention. Banks have their own obligations to the tax administration, with fines provided for in Article 129. That is why a freeze order is enforced immediately and without any negotiation at the counter.
When the obligation is not fulfilled, the administration places a security interest on movable property and a mortgage on immovable property, pursuant to Article 91. This measure requires prior notice.
The lien does not remove the property from ownership, but it prevents its transfer. In practice, this means that the vehicle, machinery, or building cannot be sold or used as collateral until the obligation is discharged. The procedure for registering security and mortgage liens is implemented in accordance with Government Decree No. 1234/2009.
The attachment takes effect 30 days after the order, pursuant to Article 93. This period expires when the collection of the obligation is deemed at risk; in such cases, the measure may be enforced immediately. The contents of the attachment order are specified in Article 94.
After seizure comes confiscation and sale at auction, pursuant to Article 96. The auction is held within 15 days, and any surplus value—that is, the portion remaining after satisfying the obligation—is returned to the taxpayer within five business days.
Article 95 removes from attachment property exempt under Article 529 of the Code of Civil Procedure. This is the basic protection of essential items and applies even when the obligation is substantial.
If a third party owes the taxpayer money, for example a client who has not paid the invoice, the tax administration may request the transfer of the amount. The third party pays within 14 days under Article 97, or within 30 days in the case of a direct request under Article 98.
For a business that has this obligation, this means that collections from registered customers can go directly into the administration's account.
Article 99 provides for joint and several liability of the partner and the administrator for tax obligations. This is the point at which the limited liability company does not function as a complete firewall, and where the obligation can be pursued against the individual, not just the NIPT.
Therefore, a remaining outstanding obligation is not resolved by leaving the company inactive. The solution lies in an agreement, an appeal, or bankruptcy proceedings under Section 104.
The tax liability becomes time-barred within five years, pursuant to Article 100. Article 102 provides for cases of interruption of the procedure, and Article 103 addresses the uncollectible liability.
Prescription is not a strategy. Deadline interruptions and administrative actions restart the clock, and in the meantime enforcement measures continue to incur costs.
Article 101 provides that the taxpayer is obligated to appear before the administration when requested. Appearance protects one's position; failure to appear weakens it.
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When a payment covers only part of the obligation, the question arises as to what is paid off first: the tax, the late‐payment interest, or the penalty. The order applied determines whether the payment stops the obligation from growing or merely reduces one of its components.
In practice, before making a partial payment, the e-Filing status is checked and the tax administration is consulted to clarify which item is being settled, because a partial payment on the wrong item does not stop the liability from increasing.
This remains the standard and most cost-effective solution. The request is made in writing, the agreement is executed within 10 days, 20% of the obligation is paid immediately, and the remainder is settled by the end of the following year. During the agreement, the penalty under Article 114 does not apply.
The agreement does not apply to withholding tax and social security and health insurance contributions.
Obligation: 5,000,000 lek. The agreement requires an immediate payment of 1,000,000 lek (i.e., 20%), and the remaining 4,000,000 lek is to be paid in installments by the end of the following year. The alternative is account freezing and a policy of no further payments to the supplier.
Read also: Installments, late fees, and non-payment penalties.
The notice and demand for payment are not read in time, and the first enforcement measure comes as a surprise.
The lifting of the block is requested from the bank, while the order comes from the tax administration.
The appeal within 30 days is not filed because it is assumed that the enforcement measure cannot be appealed.
An installment agreement is required after the freeze, when an immediate payment of 20% has become impossible.
The five-year statute of limitations is expected, while interruptions to the period restart the countdown.
The company is left passive, assuming that the obligation remains solely with the NIPT, whereas Article 99 provides for joint and several liability.
The secured property is placed under a sales pledge, and the transaction is blocked with a notary.
A partial payment is made without specifying which amount is being paid off.
Since the obligation is final and the right to appeal has been exhausted, the freeze is imposed by order of the tax administration, pursuant to Article 90.
Yes. Measures of forcible collection may be appealed within 30 days, pursuant to Article 92.
30 days after the order. When the collection of the obligation is deemed at risk, the measure is enforced without this deadline.
It will be confiscated and sold at auction within 15 days. Any surplus proceeds will be returned within 5 business days.
No. Exempt property under Section 529 of the Code of Civil Procedure is not subject to seizure under Section 95.
Article 99 provides for joint and several liability of the partner and the administrator for tax obligations.
Article 89(4)(a) provides for the requirement to impose an exit ban on the administrator, partner, or shareholder only in the event of risk.
5 years, pursuant to Article 100. The period may be interrupted and the counting resumes.
Yes, and this is the standard procedure. 20% is paid immediately, and the remainder is settled by the end of the following year, excluding withholding tax and contributions.
Law No. 9920, dated May 19, 2008, “On Tax Procedures in the Republic of Albania,” as amended, Chapter XI, Articles 88 to 104, and Articles 77, 114, and 129.
Civil Procedure Code, Article 529, on property exempt from attachment.
Government Decree No. 1234, dated December 9, 2009, on the insurance and mortgage lien; Minister of Finance's Instruction No. 24, dated September 2, 2008, as amended.