Germany and Albania have signed a protocol to amend their 2010 income tax treaty, incorporating BEPS treaty-abuse standards under the Multilateral Instrument.
Germany and Albania have signed a protocol of amendment to update their existing income tax treaty, signed on 6 April 2010.
The protocol was signed in Berlin on 9 June 2026 and covers taxes on income and on capital.
The amendment implements matching choices made under the Multilateral Convention of 24 November 2016 to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (Multilateral Instrument – MLI). It will incorporate treaty-related recommendations from the joint OECD and G20 project on Base Erosion and Profit Shifting (BEPS), including the minimum standard for preventing treaty abuse.
The Protocol must still be ratified by both Germany and Albania before entering into force.
The instruments of ratification will then be exchanged following completion of the required national legislative procedures. Once effective, its provisions will apply in both Contracting States from 1 January of the calendar year following the year in which the Protocol enters into force.
Earlier, the Albanian Council of Ministers approved a protocol to amend the 2010 income and capital tax treaty with Germany on 30 December 2025.
