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5.5. Source Rules with Respect to Income Derived by Non-Residents

Any Albanian-sourced income earned by a non-resident is subject to tax in Albania. The following income is deemed to be derived from Albania:

  • Income from a business conducted by a non-resident person, through a person with permanent residence in Albania;
  • Income from immovable property in Albania and gains from the alienation of such immovable property;
  • Dividend income distributed by a resident company;
  • Proceeds from the share of profits paid by a resident partnership;
  • Interest income paid by the government or by a resident of Albania;
  • Income from copyright and intellectual property, rent and income from gambling;
  • Effective from 1 January 2019, income from the rights for the exploitation of mineral resources, hydrocarbon resources and other rights for the exploitation of natural terrestrial and marine resources (including in Albanian territorial waters) and information pertaining to those rights, as well as gains from the alienation of such immovable property;
  • Effective from 1 January 2019, capital gains derived from the transfer of shares or similar interests if, for 365 days preceding such transfer, more than 50% of the value of the shares is derived, directly or indirectly, from immovable property, rights or related information mentioned in point (g) above;
  • Income from services rendered by a non-resident to a resident of Albania (effective from 1 January 2019, this includes income from services rendered or performed outside Albania).