Albania Transfer Pricing Documentation Requirements
Albania requires transfer pricing documentation without a threshold, produced within 45 days of a request, and an Annual Controlled Transaction Notice where controlled transactions, including loan balances, exceed ALL 50 million. A Master File may be requested from entities transacting with foreign related parties.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Entities transacting with foreign related parties (no threshold; may be requested) | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 45 days. | EN / SQ | Adjustment-based |
TP documentation Local documentation
Required | No threshold for the documentation itself | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 45 days. | EN (SQ may be requested) | Adjustment, penalties and interest where unsupported |
Controlled transaction notice ACTN
Annual filing | Controlled transactions, including loan balances, exceeding ALL 50m | By 31 March of the following year | Submission deadline The documentation must be filed with the tax authority by the date shown. | SQ | Yes |
CbC report Required | Group revenue ≥ ALL 105,000m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Albania deadline
Enter your entity’s fiscal year-end to return your exact Albania preparation or filing date. Available without registration.
Scope of the documentation obligation
The income tax law and the related transfer pricing instruction set no threshold for preparing the local transfer pricing documentation, which is produced within 45 days of a request, and a Master File may be requested from entities transacting with foreign related parties. Separately, a taxpayer whose controlled transactions, including loan balances, exceed ALL 50 million, approximately EUR 500,000, must file an Annual Controlled Transaction Notice by 31 March of the following year.
Distinctive features of the Albanian regime
The defining feature of the Albanian regime closely tracks the structure used across the region: a thresholdless documentation duty paired with a value-based notice threshold, so that all taxpayers with controlled transactions document while only those above ALL 50 million file the annual notice. Non-submission of the local documentation can lead to a price adjustment, additional income tax, penalties, and interest rather than a fixed documentation fine. Smaller taxpayers, with turnover below ALL 50 million that use external comparable data, may rely on the same data for three consecutive fiscal years, which eases the benchmarking burden at the lower end.
Benchmarking and comparables
Preference is given to local comparables; in their absence, regional comparables may be used, with differences between geographic markets and other factors taken into account. Preference is given to comparables from the same year as the controlled transaction, although immediate previous-year comparables may be relied on where the comparability criteria are met. A fresh benchmarking search is performed every three to five years in practice, with annual financial updates, and qualifying smaller taxpayers may reuse external comparable data for three consecutive years. The limitation period is five years from the date the corporate income tax return is filed.
Frequently asked questions
When must an Albanian taxpayer file the Annual Controlled Transaction Notice?
Where the aggregate value of its controlled transactions, including loan balances, exceeds ALL 50 million, approximately EUR 500,000, in the fiscal year. The notice is filed by 31 March of the following year.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.