Israel – Albania Tax Treaty

אמנת מס ישראל אלבניה

Israel – Albania Tax Treaty

albania flag

UTC:
Capital City:
Language:
Population:
Currency:
Country Code:
Domain:

+1
Tirana
Albanian
2.7 million
Albanian Lek (ALL)
+355
al.

Recent news

New Feature Enhances Invoice Tracking on Fiscalization Platform
In November 2024, the Albanian Tax Administration announced a new feature on the central fiscalization platform. Taxpayers can now see rejected electronic invoices from buyers directly in their purchase ledger. This update applies to ledger declarations beginning with November 2024, aiming to streamline invoice tracking and enhance transparency in tax reporting. With this update, buyers no longer need to manually correct the purchase ledger in Excel after the automatic transfer of ledgers to e-filing. Sellers will receive notifications about rejected invoices through the Self-Care portal, making it easier to track and verify them. This ensures that sellers can issue corrected or canceled invoices within the billing period.
Extended e-Filing Deadline for Property and Lease Reporting
The Albanian Tax Administration has extended the deadline for submitting ownership certificates and lease contracts through the e-Filing procedure to November 20, 2024. This applies to both main and secondary addresses and is essential for accurate Withholding Tax calculations and pre-filled personal income declarations. Missing the deadline will be considered an administrative offense under domestic law.
Statastical Data on Export and Inflation Rate Published for April 2024
The Institute of Statistics in Albania (INSTAT) has published key economic indicators for April 2024, including export/import levels and inflation rates. According to data reported in the official website of INSTAT, exports of goods experienced a positive trend after nearly a year of contraction, reaching a value of ALL 35 billion in April 2024. Additionally, the statistical data indicate a positive trend in the inflation rate, recorded at 2.1% in April, marking the lowest level for 2024. However, within various economic categories, the rent and energy sectors show an increasing pattern in inflation.
The Albania-Israel Economic Forum // 07.09.23
On September 7, 2023, the Israeli Embassy in Albania proudly hosted the Albania-Israel Economic Forum, a collaborative effort involving the Chamber of Commerce and Industry in Tirana, the Export Institute, and the Department of Economics at the Israeli Ministry of Foreign Affairs.  This forum was dedicated to exploring opportunities in several key sectors, including agriculture, water industry, IT and cybersecurity, tourism, and energy. The purpose of the forum was to encourage economic and commercial cooperation between the two countries. Israeli businessmen, Albanian businessmen and key people in the commercial activity in Albania attended this forum.  Throughout the event, data regarding the remarkable growth in trade volume between these two nations was presented. From 40 million euros in 2021 to 57 million euros in 2022. Notably, in the first half of 2023, the trade volume is estimated at 21 million euros.  Our firm believes in the importance of economic cooperation between the two countries and helps Israelis who want to establish activities in Albania.

Israel-Albania relations

Since 1949, the two countries have maintained excellent political and diplomatic relations, which are reflected in the intensified economic cooperation across sectors of mutual interest. Both countries have established strong bilateral relations through significant agreements, such as the Cooperation Agreement in Health and Medicine signed on November 16, 2009. Other important collaborations include the Memorandums of Understanding in Cybersecurity, and of Cooperation in Tourism, among others. Notably, in 2024 Israel and Albania facilitated the Albania-Sheba Collaboration Framework, which aims to enhance Albania’s healthcare system through immediate improvements in oncology services, including training, complex case consultations, and research collaborations. Intermediate goals focus on building essential infrastructure like electronic medical records, rehabilitation services, and transplant programs. Furthermore, as members of the United Nations, both countries collaborate on global issues aiming to benefit humanity.

Details about the Embassy of Israel in Albania

Ambassador: Ms. Galit Peleg

Address: Embassy of Israel in Tirana, Alban Tower, Rruga Ibrahim Rugova, Tirana
Phone: +35544508502
Website: Click Here
Email: cao-assistant@Tirana.mfa.gov.il

Details about the Embassy of Republic of Albania in Israel

Ambassador: Meri Kumba
Address: Laz-Rom Building, 11 Tuval Street, Ramat Gan 5252226, Israel
Phone: 03-546-5866
Website: Click Here
E-mail: embassy.telaviv@mfa.gov.al

Business Activity in Albania

Albania, with its economic resilience and a GDP of $18.2 billion, has demonstrated significant growth in the sectors of services, agriculture, and industry. Specifically, the services sector represents 47.4% of GDP and employs around 44% of the workforce, with tourism playing a significant role. The country’s strategic location and legal framework beneficial to foreign investment, alongside a commitment to sustainable energy and digitalization, position Albania as an attractive investment destination. Main exports include footwear and crude petroleum, with Italy and Greece being key trading partners. The focus on sectors driving economic growth and strategic initiatives positions Albania favorably for future investments.

To learn more about the possibilities of business possibilities in Albania, click here.

Bilateral Agreements between Albania and Israel

 

Several agreements were signed between Israel and Albania:

  1. International Investment Agreement
  2. Double Taxation Agreement

Reciprocal Promotion and Protection of Investments

The Reciprocal Promotion and Protection of Investments (RPPI) was signed in 1996 and went into effect in 1997. The RPPI is an agreement between Israel and Albania that is designed to encourage and safeguard investments made by individuals and companies from each country in the territory of the other. These agreements typically include provisions related to non-discrimination, compensation for expropriation, dispute resolution, and the transfer of funds.

To read the agreement in English, click here.

Convention on the Prevention of Double Taxation

The agreement between the Governments of Israel and Albania regarding the avoidance of double taxation was signed on 2.5.2021 and entered into force on 31.12.2021.

To read the agreement in English, click here.

Residency for Tax Purposes in Albania

 

Residence of an Individual

A person is considered a resident of Albania if they have a permanent home there or if they stay in the country for more than 183 days in a calendar year, whether continuously or not, regardless of their citizenship or main place of interest.

To read about how an individual is considered a resident of Israel, click here.

Residency of a Company

A legal entity gains resident status in Albania for tax purposes if it meets any of the following criteria:

  1. It maintains its headquarters within the Republic of Albania;
  2. Its center of business management is effectively in Albania.

To learn about how a company is considered a resident of Israel, click here.

Nimrod Yaron and albanian ambassador

The Tax System in Albania

Albania Tax Authority is called The General Directorate of Taxation.

Income Taxation: 13%, 23%

Taxation of Companies and Branches: 15%

VAT: 20%

Capital Gains Tax: 15%

Withholding Tax

 

Albania Internal Tax Rate

Israel Internal Tax Rate

Treaty Withholding Tax

Personal Income tax (Tax brackets)

• For annual taxable income up to ALL 2,040,000 – 13%;

and

• For annual taxable income over ALL 2,040,000 – 23%.

Up to 50%

 

 

Corporate Income Tax

15%

23%

 

Capital Gains Tax Tate

15%

25%-30% (with anadditional surtax of 3% applied to high earners)

 

Branch Tax

15%

23%

 

Withholding tax

(Non-Resident)

Dividends

 

8%

 

25% or 30%

 

5%/8%

Interest

 

15%

15%/25%/23%

10%

Royalties

15%

23%-40%

5%

 

VAT

 

20%

 

17%

 

Inheritance Tax and Estate Tax in Albania

The tax rate for inheritances and gifts income is 15%, with no deductions for any costs.

Tax Exemptions:

  1. Donations and inheritances between legal heirs of the first and second degree, as well as between siblings.
  2. Donations and inheritances up to 5,000,000 ALL for immovable assets and up to 1,000,000 ALL for movable assets are not covered in point (a).
  3. The transfer of ownership rights to legal heirs through gifts or relinquishment applies to property acquired as compulsory co-ownership under Law No. 7501, dated 19 July 1991, “On Land,” as amended.

Relocation to Albania

Albania offers a strategic opportunity for business expansion or relocation due to its unique geographical position in Southeast Europe, dynamic young population, and rich natural resources, highlighting its significant economic potential. The country demonstrates positive economic growth trends with fiscal consolidation, reduction in budget deficit and public debt, and stable economic conditions. Furthermore, it benefits from a regional market approach within the CEFTA countries, targeting full European market integration.

The Albanian business environment is increasingly favorable, marked by growing confidence and a consolidating production structure that enhances export value. The government’s reforms aim to improve the business climate, productivity, and competitiveness, and attract domestic and foreign investments.

Albania ranks favorably in investor protection and trade facilitation, reflecting its commitment to international standards. Albania’s strategic location, economic potential, favorable business environment, and comprehensive reforms make it an attractive destination for businesses aiming for relocation or expansion, positioning Albania as a prime market destination within regional and European contexts.

Real Estate Taxation in Albania

The property tax rates in Albania for buildings are determined by their use and value, applying specific percentages to calculate the due tax annually. For residential properties, the tax rate is 0.05% of the property’s value. Commercial properties are taxed at a higher rate of 0.2% of their value. Unfinished construction projects that exceed the completion deadline specified in their construction permit are subject to a significantly higher tax rate of 30% of the property’s value.

In addition, a transfer tax, charged by local authorities, is applicable on the transfer by business entities of title to buildings or other real estate. This tax is levied at higher rates in cities such as Tirana and Durres, while the rates are lower in other areas of the country. All other real property is taxed at a rate of 2 percent of the sale price.

Transfer of Funds from Israel to Albania

According to section 170(a) of the Israeli Income Tax Ordinance, all payments transferred to non-Israeli residents are subject to a 25% withholding tax. However, this tax can be reduced or even waived if certain conditions are met. Our firm handles withholding tax matters with the Israeli Tax Authority.

As mentioned above, the countries have signed a tax treaty, that allows taxpayers to submit a 2513/2 form – Statement regarding a payment to a foreign resident that is exempt from withholding tax, to potentially transfer the payments without paying the withholding tax. 

In addition to assisting with withholding tax matters, our firm also helps with other issues related to transferring funds abroad. This includes providing an accountant’s approval regarding the payment of taxes, reviewing additional actions required under the CRS standard, and more. 

Moreover, banks often raise many difficulties and charge high fees for converting shekels into other currencies. Therefore, consulting with a specialist before transferring the funds is highly recommended, click here to contact us

For more information on money transfers abroad, click here

Types of Business Entities in Albania

In Albania, business activities can be conducted through various types of entities:

  • General Partnership – A business entity with at least two partners sharing unlimited liability for the company’s debts. Assets and profits are distributed as per the partnership agreement.
  • Limited Partnership – Consists of limited and general partners. Limited partners contribute financially and have limited liability at their investment, whereas general partners hold unlimited liability and manage the business.
  • Limited Liability Company (LLC) – The most common form in Albania, where shareholders invest capital and their liability is restricted to their investment, shielding personal assets from company debts.
  • Joint Stock Companies (Sha) – This type of business form is designed for large enterprises, raising funds by offering shares to the public. Their capital is divided into shares subscribed by founders, who are not personally liable beyond their contributions. A Sha is established through a Founding Shareholders’ Meeting to subscribe shares and adopt the Statute, becoming operational after registration in the Commercial Register. The minimum capital is ALL 3,500,000 for private offerings and ALL 10,000,000 for public offerings, with at least 25% of cash contributions paid before registration. Sha is the only Albanian legal entity permitted to issue bonds.
  • A Joint Venture – Joint ventures are unlimited partnerships formed by individuals or entities to undertake economic activities or projects, sharing costs and profits. They have no capital requirements, and partners are jointly liable for obligations defined by their agreement and law. Registration in the commercial registry is declaratory and does not grant legal personality.

Incentive Laws in Albania

In Albania, investment incentives include a range of fiscal, financial, and other benefits designed to stimulate domestic and foreign investments in various sectors, including technology, agriculture, tourism, and renewable energy. Here’s a detailed overview of specific incentives available:

Fiscal Incentives

  1. Loss Carry Forward: Corporate income tax losses can be carried forward for three consecutive years.
  2. VAT Exemption: There are exemptions for solar panel systems, agricultural machinery, books, and large electric vehicles. VAT for agritourism activities and audio-visual media services is reduced to 6%.
  3. Tax Exemption on Dividends: Dividends designated for investments are exempt from corporate income tax.
  4. Guaranteed Feed-in Tariff: For renewable energy generation, ensuring a fixed purchase price for generated electricity.

Financial Incentives

  • Subsidized Land Concession: Public property of more than 500 square meters can be leased or granted for a symbolic price of 1 euro for manufacturing or inward processing activities exceeding an investment of 10 million euros.
  • Technological and Economic Development Area (TEDA) Incentives: Include VAT and customs duty exemptions, capital expenditure deductions, personal income tax exemption, and real estate/infrastructure tax exemptions among others.

Sector-Specific Incentives

  • Reduced Profit Tax: For software producers, agricultural producers, and agritourism activities, the applied income tax rate is 5%.
  • Exemption from Carbon Tax: Exported petrol and gasoline are exempt.
  • Import Duties Exemption: For machinery used in renewable energy production and various other sector-specific machinery and equipment.

These incentives are part of Albania’s broader strategy to attract investment, stimulate economic growth, and align with European Union standards. To read more on the tax incentives in Albania, click here.

Albania: Double Tax Treaties

Austria

Hungary

Malta

Spain

Belgium

Iceland

Moldova

Slovenia

Bosnia and Herzegovina

India

Morocco

Sweden

Bulgaria

Ireland

Netherlands

Switzerland

China

Israel

Norway

Turkey

Croatia

Italy

Poland

United Arab Emirates

Czech Republic

Korea

Qatar

United Kingdom

Egypt

Kosovo

Romania

 

Estonia

Kuwait

Russia

 

Finland

Latvia

Saudi Arabia

 

France

Luxembourg

Serbia & Montenegro

 

Germany

Macedonia

Singapore

 

Greece

Malaysia

Slovakia

 

 

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