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Dorina Ndreka |
Albania and the Kingdom of Morocco preliminarily agreed on the need for an agreement on the avoidance of double taxation (DTA) back in 2012 when treaty negotiations commenced. The willingness to conclude such an agreement was reiterated in October 2014 during Albanian parliamentary officials' visit to Morocco. The treaty was finally signed during the visit of the Albanian Minister of Foreign Affairs to Morocco in October 2015.
The aim of the agreement, which will enter into force after Albania's ratification, is to prevent fiscal evasion and avoid double taxation, especially on income tax.
Both countries are members of the OECD Convention on Mutual Administrative Assistance in Tax Matters and the treaty concluded closely follows the OECD model. The treaty deems a permanent establishment to include a construction or installation site or project (or supervision of such a site/project) in duration exceeding six months as well as the provision of services (including consulting) that lasts for an aggregate period exceeding one month in a 12-month period.
As far as withholding taxes are concerned, the agreement defines a withholding tax rate of 10% on dividend payments as well as on royalties and interests.
After the signing of the treaty in October 2015, the Moroccan Government approved the treaty on December 16 2015 while the Council of Ministers approved it on February 6 2016. Albania's ratification is still pending.
The DTA between Albania and Morocco is seen as a progressive and important step for exploring opportunities of improved economic cooperation, particularly in trade, agriculture and tourism, as well as for strengthening bilateral relations.
Dorina Ndreka (tirana@eurofast.eu)
Eurofast
Tel: + 355 (0) 42 248 548
Website: www.eurofast.eu
