Albania: Country-by-country reporting legislation implemented

Albania has implemented provisions regarding country-by-country (CbC) that contain detailed rules and procedures to be followed by ultimate parent entities and constituent entities of a multinational enterprise (MNE) group when preparing the CbC report and notification to the tax administration.

Each ultimate parent entity of a multinational enterprise (MNE) group that is resident in Albania for tax purposes must prepare and submit to the Albanian tax authorities a CbC report in accordance with the requirements of the law. MNE groups having total consolidated group revenue of less than ALL 105 billion during the fiscal year preceding the reporting fiscal year as reported in its consolidated financial statement are not required to prepare and submit a CbC report.

The CbC report is filed by the reporting entity using the XML schema in accordance with the taxpayer’s manual for CbC reporting approved by the General Directorate of Taxes, which is prepared referring the OECD’s XML schema and user guide for CbC reporting.

The taxpayer's manual for CbC reporting must contain the information required to be included in each data element of the CbC report, as well as instructions on how to make corrections to data items within a file, that can be processed automatically.

The CbC report must be filed no later than 12 months after the last day of the reporting fiscal year of the MNE group. Failure to file the CbC report within the deadline is subject to a penalty of ALL 10,000 for each month of delay up to 12 months after the deadline. If the report is not filed after 24 months from the deadline, the taxpayer is subject to a penalty of ALL 200,000. In case the taxpayer provides incorrect or incomplete information through the CbC report, it is subject to a penalty of ALL 50,000.

Read a September 2024 report prepared by the KPMG member firm in Albania