Albania enacted regulations on 11 August 2024, concerning country-by-country (CbC) reporting, outlining specific rules and procedures that ultimate parent entities and constituent entities of a multinational enterprise (MNE) group must follow during the preparation of CbC reports and sending notifications to tax authorities.

This decision was implemented after Albania published Decision No. 513, dated 1 August 2024, in the Official Gazette.

Earlier, on 11 March 2024, Albania signed the CbC Multilateral Competent Authority Agreement (MCAA). This agreement enables tax authorities from various countries to automatically exchange financial information. The agreement also plays a vital role in combating tax evasion and promoting equitable taxation across borders.

All ultimate parent entities of multinational enterprises (MNEs) in Albania must submit a CbC report to tax authorities, unless their total consolidated group revenue is below ALL 105 billion in the preceding fiscal year.

The CbC report is filed by the reporting entity using an XML schema based on a taxpayer manual approved by the General Directorate of Taxes, which aligns with the OECD’s guidelines. The manual must include the required information for each data element of the CbC report and provide instructions for rectifying data items automatically.

Penalties

The CbC report must be filed within 12 months of the MNE group’s reporting fiscal year.

Late submissions incur a penalty of ALL 10,000 per month for up to 12 months. If the CbC report is not filed within 24 months, the penalty increases to ALL 200,000. Additionally, providing false or incomplete information will result in a penalty of ALL 50,000.