Albania: Transfer pricing: A step forward for Albania

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Albania: Transfer pricing: A step forward for Albania

sagianni.jpg

lena.jpg

Anastasia Sagianni


Erion Lena

The Albanian Ministry of Finance issued informative administrative guidelines for taxpayers related to the new transfer pricing legislation. According to the "Instruction on transfer pricing" published in June 2014, the Ministry of Finance sheds light on notorious issues as far as taxpayer compliance obligations are concerned. Apart from the Transfer Pricing File, taxpayers in the Republic of Albania are obliged to complete the Controlled Transaction Notice as described in Appendix 2 of the June Instruction.

Transfer pricing documentation must be updated annually. Taxpayers are obliged to submit the TP study within 30 days from the request of the tax authorities, while the declaration of intra-group transactions accompanied with the TP method applied for each instance must be completed annually and submitted concurrently with the income tax return in the form of a Controlled Transaction Notice.

The threshold amount was set to ALL 50,000,000 ($450,000 / €357,000). Pursuant to Article 36/5, paragraph 2, of the Income Tax Law (no. 8438), taxpayers engaging in controlled transactions (including loan balances), which in aggregate, within the reporting period, exceed ALL 50,000,000 are required to complete and submit the Annual Controlled Transactions Notice.

The same amount of ALL 50,000,000 defines the taxpayer's obligation related to yearly updates of the comparable set. In line with the above, in the case of a benchmarking analysis using external comparables, the set of external comparable uncontrolled transactions is updated only every third reporting period provided there have been no material changes to the controlled transactions, the external comparable uncontrolled transactions or the relevant economic circumstances.

Transfer pricing documentation may be submitted in Albanian or English language. However, if documents are submitted in English, the tax authority has the right to request the translation of English documents into Albanian. By accepting the English language in the documentation, the Albanian tax authorities have already made a great first step towards harmonisation with the suggestions released on September 16 2014 in the Guidance on Transfer Pricing Documentation and Country-by-Country Reporting, (D.6, Chapter V, Action 13, BEPS).

According to paragraph 2 of the recently introduced administrative guidelines by the Albanian Ministry of Finance, though it is clarified that Albanian Law follows OECD Guidelines (OECD TPG 2010), in case of differences or conflicts between the OECD TPG 2010 and Albanian Income Tax Law and Instructions, the Albanian Income Tax Law and Instructions will prevail.

Anastasia Sagianni (anastasia.sagianni@eurofast.eu) and Erion Lena (erion.lena@eurofast.eu)

Eurofast Global, Tirana Office

Tel: +355 69 533 7456

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Overall revenues for the combined UK and Swiss firm inched up 2% to £3.6 billion despite a ‘challenging market’
In the first of a two-part series, experts from Khaitan & Co dissect a highly anticipated Indian Supreme Court ruling that marks a decisive shift in India’s international tax jurisprudence
The OECD profile signals Brazil is no longer a jurisdiction where TP can be treated as a mechanical compliance exercise, one expert suggests, though another highlights 'significant concerns'
Libya’s often-overlooked stamp duty can halt payments and freeze contracts, making this quiet tax a decisive hurdle for foreign investors to clear, writes Salaheddin El Busefi
Eugena Cerny shares hard-earned lessons from tax automation projects and explains how to navigate internal roadblocks and miscommunications
The Clifford Chance and Hyatt cases collectively confirm a fundamental principle of international tax law: permanent establishment is a concept based on physical and territorial presence
Australian government minister Andrew Leigh reflects on the fallout of the scandal three years on and looks ahead to regulatory changes
The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Gift this article