On 26 March 2013, Albania and the United Kingdom signed a Double Taxation Agreement.
The agreement generally follows the provisions of the OECD Model, with some modifications. The agreement will enter into force when the appropriate ratification procedures have been completed in both countries and the countries have exchanged diplomatic notes.
Under the agreement the definition of a permanent establishment for the purposes of business taxation in the source country generally follows the OECD Model but a building site or construction or installation project will constitute a permanent establishment if it continues for at least six months.
The maximum withholding tax rate on dividends is generally 10%, reduced to 5% if the recipient company owns at least 25% of the company paying the dividend. A maximum 15% withholding tax rate applies if the dividends are paid out of income received directly or indirectly from immovable property by an investment vehicle which distributes most of this income yearly and whose income from such immovable property is free from tax.
The maximum withholding tax rate on interest is 6%. There is an exemption from withholding tax on interest if the beneficial owner is the State, a financial institution or a pension scheme. There is also an exemption from withholding tax if the interest is paid on debt arising from the sale on credit of any equipment, merchandise or services. No withholding tax applies to royalty payments.
The Article in relation to the mutual agreement procedure provides for the issues to be submitted to arbitration where the competent authorities have been unable to reach agreement within a period of two years. The agreement also includes Articles in respect of the exchange of information and assistance in the collection of taxes.