Albania’s parliament is examining a draft law to ratify the Multilateral Convention that enables implementation of the Pillar Two Subject to Tax Rule (STTR), following the country’s signing of the agreement in September 2025.
Albania’s parliament is reviewing a draft law, submitted on 9 March 2026, aimed at ratifying the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI).
Albania signed the STTR MLI on 23 September 2025, enabling the STTR to be applied in bilateral tax treaties. It became the 10th jurisdiction to do so.
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.
Earlier, the OECD announced that Albania signed the Multilateral Convention for the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI).
