Albania became the 10th country to sign the STTR MLI, the OECD confirmed.
The OECD announced that Albania signed the Multilateral Convention for the Implementation of the Pillar 2 Subject to Tax Rule (STTR MLI) on 23 September 2025.
Albania is the 10th jurisdiction to sign the STTR MLI.
The Pillar Two Subject to Tax Rule (STTR) is a treaty-based rule applying to a defined set of cross-border intragroup payments. Where these payments are subject to a corporate income tax rate below 9% in the recipient’s jurisdiction of residence, it allows the jurisdiction of source to apply additional tax up to that minimum rate.
Members of the Inclusive Framework on BEPS that apply nominal corporate income tax rates below 9% to income covered by the STTR have committed to incorporate the STTR into bilateral tax agreements with Members of the Inclusive Framework that are developing countries when requested to do so.
The Inclusive Framework adopted the STTR MLI to enable the implementation of the STTR in existing bilateral tax treaties without the need for bilateral amendments.
