The France-Albania tax treaty: dividends at 5% or 15%, interest at 10%, royalties at 5%.

The France-Albania convention caps the tax levied by the state of source at 5 or 15 for dividends, 10 for interest, and 5 for royalties. It was signed in Tirana on December 24, 2002, and entered into force on October 1, 2005.

A text from 2002, the MLI since 2021

The text has been applicable since January 1, 2006 (Article 30). A ten-point protocol forms an integral part of the convention. The administrative list (BOI-ANNX-000306, dated April 29, 2026) classifies it among the conventions on income and wealth and does not mention any provisions on inheritance or gifts. The multilateral convention (MLI) entered into force in France on January 1, 2021, for taxes withheld at source and on July 1, 2021, for other taxes. It adds a rule: an advantage is not granted if obtaining it was one of the principal objectives of an arrangement, unless it complies with the object and purpose of the convention.

Albania: Maximum detentions and key rules

Dividends of €50,000: a numerical example (fictitious profile)

Situation. A partner (company or natural person), fictitious profile, receives €50,000 in gross dividends from an Albanian company.

Issue. He wants to know the maximum amount that the convention allows Albania to retain.

Strategy. First, it checks if it is a company holding at least 25 % of the capital throughout 365 days, then applies the ceiling of Article 10 § 2.

Result. At 5 %, the ceiling is €2,500. At 15 %, it is €7,500, i.e., €5,000 more. These are maximums stipulated by the agreement, not the tax due.

Dual residence: the order of article 4

For a natural person resident in both States, Article 4 § 2 considers in order the permanent home (then the center of vital interests), the habitual residence, the nationality, then the agreement of the competent authorities.

Salaries, pensions, wealth

Article 15, paragraph 2, sets the threshold at 183 days over any twelve-month period beginning or ending in the tax year in question. Article 18 reserves the taxation of private pensions to the State of residence, subject to Article 19, paragraph 2. Article 23 attributes real estate assets to the State where the property is located and the remainder to the State of residence. The text refers to the wealth tax; its application to the IFI (French real estate wealth tax) is not established.

Eliminating double taxation in France

Article 24 provides for a tax credit against French tax for income taxable in Albania, of two kinds. For most types of income, the credit is equal to the corresponding French tax, and for income covered by Articles 7, 10, 11, 12, 13 § 1 and 2, 15 § 3, 16 and 17 § 1 and 2, to the Albanian tax credit, subject to a cap, for income covered by Articles 7, 10, 11, 12, 13 § 1 and 2, 15 § 3, 16 and 17 § 1 and 2. See the text for the cap.

What this sheet does not cover

Albanian tax rates, permanent establishments, exchange of information, mutual agreement procedure, wealth tax, gifts and other points of the protocol are not addressed.

What changes depending on your situation

Your residence, the nature of your income, your custody status, and its duration are all factors. Each article is interpreted in light of the facts of your case, and no outcome is guaranteed.