The German Ministry of Finance recently announced the signing of an amending protocol to the 2010 income and capital tax treaty with Albania on 9 June 2026. The protocol is the first to amend the treaty and includes the following changes:
- The preamble is replaced in line with OECD BEPS standards;
- Paragraph 2 of Article 10 (Dividends) is replaced, providing for a withholding tax rate of 5% if the beneficial owner of the dividends is a company (other than a partnership) that directly holds at…