DT2252 - Double Taxation Relief Manual: Guidance by country: Albania: Treaty summary

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Albania are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk.

Subject	Comments	Article
Portfolio dividends	10%	10
Dividends on direct investments	5%	10
Conditions for lower rate on dividends on direct investments	The beneficial owner must be a company which controls directly, at least 25% of the capital of the payer	10
Property income dividends	15%	10
Interest	6% (Note 1)	11
Royalties	0%	12
Government pensions	Taxable only in Albania	18
Other pensions	Taxable only in Albania	17
Arbitration	Yes	25

Note 1: Interest paid in the following circumstances is taxable only in the state of residence of the beneficial owner of the interest:

• the UK Government, the Bank of England, a political sub-division, or a local authority
• a resident of the UK and the interest is paid by Albania or one of its political subdivisions or local authorities
• a resident of the UK and the interest is paid in respect of a loan or debt owed to, or made, guaranteed or insured by the UK Government or a political subdivision, local authority, or export financing agency
• a financial institution
• a resident of the UK and the interest is paid with respect to indebtedness arising from the sale on credit of any equipment, merchandise or services
• a pension scheme