DT2252 - Double Taxation Relief Manual: 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