Albania deposited its instrument of ratification for the Pillar Two Subject to Tax Rule (STTR) MLI on 15 September 2026. The convention provided a framework for implementing the STTR through Albania’s bilateral tax treaties.
The OECD reported that Albania deposited its instrument of ratification for the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR MLI) on 15 September 2026.
Albania signed the STTR MLI on 23 September 2025, establishing a framework for implementing the STTR through its bilateral tax treaties. The STTR allows jurisdictions to “tax back” where defined categories of income are subject to nominal tax rates below the STTR minimum rate of 9% and domestic taxing rights over that income have been ceded under a treaty.
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.
It is designed to help developing countries, in particular, to protect their tax base.
