Page 7 - Central and Eastern European Transfer Pricing Review

Albania | 7

Do tax authorities have Tax treaty/double tax Does the tax authority publish APA
requirements or preferences resolution data, either in the form of an annual
regarding databases for report or through the disclosure of
comparables? What is the extent of the double tax data in public forums?
No. treaty network? Not applicable.
Currently, there are 34 double tax treaties
What level of interaction do tax in force signed between Albania and Please provide some information
authorities have with customs other countries. on how successful the APA program
authorities? is and whether there are any known
Interaction between tax and customs If extensive, is the competent diffculties?
authorities regarding VAT is high. authority effective in obtaining Not applicable.
However, it is not possible to estimate double tax relief?
the level of interaction regarding transfer Not applicable. Language
pricing.
When may a taxpayer submit an In which language or languages can
Are management fees deductible? adjustment to competent authority? documentation be fled?
Generally, yes. Please note that non- There are no specifc transfer pricing Albanian.
documented costs are non deductible, rules. Based on the general provisions
as are costs that are not incurred for of the Albanian tax law, the adjusted
business purposes. tax declaration should be submitted
within 12 months from the deadline of
Are management fees subject to submission of the frst tax declaration.
withholding?
Yes, 10 percent withholding tax may May a taxpayer go to a competent
apply, unless there is a double tax treaty authority before paying tax?
between Albania and the country of the No formal rules exist regarding this.
benefcial owner of the income.
Advance pricing
Are year-end transfer pricing
adjustments permitted? arrangement
No relevant practice has been observed. What APA options are available, if
any?
Other unique attributes?
The law provides the possibility for the
Not applicable. tax authorities to enter into an APA with
taxpayers or tax authorities in other
Other recent countries. However, no APA has been
developments implemented in practice up to now.
The Albanian General Tax Directorate Is there a fling fee for APAs?
is creating a special unit which shall No.
specialize in transfer pricing issues.
However, the project is in the initial
stages.

KPMG in Albania

Arkadiusz Mierzejewski
Tel: +359 2 9697 700
Email: arekmierzejewski@kpmg.com

As email addresses and phone numbers
change frequently, please email us at
transferpricing@kpmg.com if you are unable
to contact us via the information noted above.
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