{"id":45369,"date":"2026-05-23T21:48:49","date_gmt":"2026-05-23T21:48:49","guid":{"rendered":"https:\/\/alprofitconsult.al\/?p=45369"},"modified":"2026-05-24T13:59:17","modified_gmt":"2026-05-24T13:59:17","slug":"albania-ratifies-the-oecd-sttr-convention-with-law-no-45-2026","status":"publish","type":"post","link":"https:\/\/alprofitconsult.al\/en\/shqiperia-ratifikon-konventen-sttr-te-oecd-me-ligjin-nr-45-2026\/","title":{"rendered":"Albania ratifies the OECD STTR Convention via Law No. 45\/2026"},"content":{"rendered":"

On April 23, 2026, the Assembly of the Republic of Albania adopted Law No. 45\/2026<\/a> 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.<\/p>\n\n\n\n

The Convention is internationally recognized as the STTR instrument, an abbreviation for the Subject to Tax Rule<\/a>It was developed by the OECD\/G20<\/a> Inclusive Framework on Base Erosion and Profit Shifting (BEPS) and was approved in Paris on September 15, 2023.<\/p>\n\n\n\n

The new regulation affects a specific category of cross-border payments within related groups of companies. For most small Albanian businesses, the direct impact is limited. However, companies with an international group structure must fully understand the consequences of this law.<\/p>\n\n\n\n

Read also The CRS\/AEOI Framework and Albania: Automatic Exchange of Information<\/a><\/p>\n\n\n\n

What is the Multilateral STTR Convention?<\/h2>\n\n\n\n

The Multilateral Convention is a technical instrument that simultaneously modifies existing double <\/a>tax treaties between Albania and other signatories. Without this instrument, each bilateral treaty would need to be renegotiated individually\u2014a process that would take decades.<\/p>\n\n\n\n

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%.<\/p>\n\n\n\n

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.<\/p>\n\n\n\n

\nRequest a Free Consultation<\/a>\n<\/div>\n\n\n\n

Who is affected and who is not?<\/h2>\n\n\n\n

Typical clients of AlProfit Consult<\/a> \u2014small and medium-sized Albanian businesses operating domestically\u2014are 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.<\/p>\n\n\n\n

The STTR Convention addresses the shifting of profits by multinational groups toward low-tax jurisdictions. Specifically, it affects:<\/p>\n\n\n\n