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7 October 2026
A building project can produce very different accounting and tax results for the businesses involved. The contractor earns a fee for carrying out the works. The investor acquires or develops a property to sell, rent or use. A corporate landowner may sell its land, exchange it for units in the completed building, or participate in a development venture. Each business needs to account for its own rights and obligations.
The starting point is therefore the role of each party and the substance of each agreement. A payment, a progress certificate and a property transfer can occur at different dates, and each can have a different effect on revenue, VAT and taxable profit. This article explains those differences for business-to-business transactions in Albania, with particular attention to companies. Personal taxation of an individual landowner is outside its scope.
All worked examples use ALL million unless stated otherwise. Dr means debit and Cr means credit. Figures exclude VAT unless expressly shown. Account names are illustrative; map them to the entity’s chart of accounts. Corporate tax illustrations assume the standard 15% rate applies, with no tax losses, credits or other adjustments unless specified.
|
Business role |
What the business records |
Main tax question |
|
Investor or developer |
Property under development, then inventory, investment property or an asset for own use |
Is the eventual supply taxable or exempt from VAT, and which costs are deductible? |
|
Contractor or subcontractor |
Construction revenue and the costs of work performed for a customer |
How do progress, monthly invoicing, advances and the long-term contract rules interact? |
|
Corporate landowner |
Land disposal or exchange, rights to receive units, and the property ultimately received |
Does the land-for-building exchange rule apply, and what tax basis carries into the later disposal? |
|
Investor and contractor in one company |
The company’s own development costs and sales to external customers |
How is VAT self-supply reported without creating accounting profit from an internal transaction? |
Law No. 25/2018 on accounting and financial statements, as amended, determines the reporting framework. The applicable framework must be established under that law; obtaining foreign finance does not, by itself, make IFRS mandatory. This article explains the ordinary SKK framework and identifies material differences for businesses applying full IFRS. [1]
The current SKK set became effective on 1 January 2025. The main standards here are SKK 4 for inventories, SKK 5 for tangible and intangible non-current assets and investment property, SKK 6 for provisions, SKK 8 for revenue, and SKK 11 for income tax. SKK 8 still contains specific construction-contract requirements. The revised SKK 8 published for comment on 30 September 2026 is a consultation document and is not treated here as an effective replacement. [2–3]
For full IFRS reporting, IFRS 15 governs customer revenue, with IAS 2, IAS 16, IAS 40, IAS 23 and IAS 37 addressing relevant assets, borrowing costs and provisions. IFRS 15 replaced IAS 11. Its requirements should not be mixed selectively with SKK requirements in the same statutory financial statements. [4]
Taxable profit starts from the accounting records and is adjusted under Law No. 29/2023, as amended, its implementing Instruction No. 26/2023 and Council of Ministers Decision No. 753/2023. VAT follows Law No. 92/2014 and Instruction No. 6/2015, as amended. A difference between a tax return and the financial statements therefore needs an explanation, rather than an automatic change to accounting revenue. [5–8]
An investor that engages a separate contractor normally records the work acquired as part of its property development. If the units are held for sale in the ordinary course of business, they are inventories under SKK 4. If the completed building will house the investor’s own operations, it is an asset for own use under SKK 5. Property held to earn rentals or for capital appreciation is assessed under the investment-property provisions. A building with several uses may require separate accounting for identifiable parts. [2]
This classification determines the subsequent expense pattern. Inventory cost becomes cost of sales when the related units are sold and revenue is recognised. An owner-occupied building is depreciated when available for use. Land is accounted for separately and is not depreciated. Investment property follows its applicable measurement model.
An investor that merely lends money to the developer has a financial asset and financing income, rather than ownership of construction inventory. Similarly, a genuine joint venture needs an analysis of the parties’ contractual rights and control. Calling an agreement an “investment contract” does not settle either question.
Development cost normally includes the attributable land cost, construction invoices, directly attributable design and permit expenditure, and other costs required to bring the property to its present location and condition. Irrecoverable VAT forms part of the relevant cost. Selling expenditure and general administration that does not contribute to preparing the property are expensed. Abnormal waste should not be hidden in the carrying value of unsold units. [2]
Allocate common costs using a reasoned, consistent basis. Floor area may work for comparable apartments, but a shop, a basement parking space and a residential unit can require different allocations. Maintain a schedule reconciling the whole project’s cost to sold units, unsold units, retained property and units owed to a landowner.
Borrowing costs require particular care. SKK 5 paragraph 15 requires borrowing costs to be expensed as incurred. Full IFRS can produce a different answer: IAS 23 requires eligible borrowing costs directly attributable to a qualifying asset to be capitalised. A financing cost should not be added to a development merely because the project lasts several years. [2, 9]
For an ordinary property sale under SKK 8, assess the transfer of significant risks and rewards, the absence of continuing control of the kind associated with ownership, reliable measurement and probable economic benefits. Signing a reservation agreement or receiving an instalment is not sufficient on its own. Handover, acceptance, enforceable contractual rights and title documentation need to be read together. [2]
An advance received from a buyer is initially a liability where the sale-recognition conditions have not been met. The physical completion percentage of the building does not automatically become the investor’s sales-revenue percentage. First determine whether the particular agreement is a sale of a property or a construction contract within the applicable standard.
Under IFRS 15, assess whether the relevant performance obligation qualifies for recognition over time. In particular, the criterion concerning an asset with no alternative use also requires an enforceable right to payment for work completed to date. Both conditions must be met for that criterion. The other over-time criteria concern simultaneous receipt and consumption of benefits, or a customer-controlled asset being created or enhanced. If none applies, revenue is recognised when control transfers. [4]
Ordinary construction services are subject to 20% VAT. By contrast, the supply of a building or part of a building and its underlying land is generally exempt under Article 53(g) of the VAT law. This distinction also applies when the buyer is another business. A B2B sale is not automatically taxable, and exemption is different from a zero-rated supply. Specific statutory exemptions and valid options to tax must be considered separately. [7–8]
An investor buying construction work for an exempt property sale generally cannot deduct the related VAT. The contractor charges VAT on its service; the investor includes the non-deductible amount in development cost. Where the investor uses the building for taxable operations, deduction may be available subject to the normal conditions. Mixed use requires an allocation and, where applicable, subsequent VAT adjustments.
A contractor invoices 10.00 plus VAT of 2.00. The invoice is valid and the work is attributable wholly to the stated use. [2, 7–8]
|
Item |
Units for exempt sale |
Warehouse for taxable own operations |
|
Construction invoice |
Net 10.00 + VAT 2.00 = payable 12.00 |
Net 10.00 + VAT 2.00 = payable 12.00 |
|
Debit |
Development inventory 12.00 |
Construction in progress 10.00; deductible VAT 2.00 |
|
Credit |
Contractor payable 12.00 |
Contractor payable 12.00 |
|
VAT effect |
No deduction of the 2.00; it enters inventory cost |
Deduction of 2.00, subject to normal eligibility conditions |
|
Later accounting |
Release the allocated cost when the relevant units are sold |
Transfer to the building account when ready for use; start depreciation |
|
Evidence |
Contract, works statement, invoice and allocation to units |
The same documents, plus evidence of qualifying taxable use |
Do not deduct input VAT simply because the investor and contractor are both VAT-registered businesses.
An advance for a future exempt building sale is also invoiced as exempt under Article 20 of Instruction No. 6/2015. It must not be confused with an advance for taxable construction work. [8]
Decision No. 753/2023 distinguishes investors and sellers from contractors. For an investor that owns the development product, business income arises from sales and from renting the retained part. Tax calculations must take account of the applicable minimum sale-price and rental-reference rules. These fiscal references do not automatically replace the accounting measurement of the transaction. [6]
The sale meets the accounting recognition criteria. The unit sells for 18.00 and its inventory cost is 12.00, including irrecoverable VAT. Assume an exempt building sale, an accepted tax selling value and fully deductible cost. [2, 5–8]
|
Step |
Calculation or journal entry |
Result |
|
Recognise the sale |
Dr trade receivable 18.00; Cr property sales 18.00 |
Revenue 18.00; no output VAT on this exempt supply |
|
Release inventory |
Dr cost of sales 12.00; Cr completed-unit inventory 12.00 |
Cost of sales 12.00 |
|
Gross profit |
18.00 − 12.00 |
6.00 |
|
Illustrative corporate tax |
6.00 × 15% |
0.90, assuming this is also the taxable profit |
|
Record current tax |
Dr current income-tax expense 0.90; Cr tax payable 0.90 |
Current tax liability 0.90 |
|
Collect the price |
Dr bank 18.00; Cr trade receivable 18.00 |
Receivable cleared; no second recognition of revenue |
In practice, reconcile the tax selling value, land-cost conditions and other deductions before using the illustrative taxable profit.
Unsold units remain inventory, subject to the applicable recoverability assessment. Buying land or paying the contractor does not make the whole payment an immediate deductible expense. Decision No. 753/2023 specifically allows the carrying value of purchased land attributable to sold building space to be deducted where the relevant land is deregistered from the entity at ASHK and transferred to the buyers. Land attributable to property retained for the company’s own use or rental does not receive that immediate deduction. [6]
The contractor’s product is the construction service promised to its customer. Its customer may be an investor, another contractor or a corporate landowner. Under SKK 8, where the outcome can be estimated reliably, revenue and related expenses are recognised by reference to progress. This requires a supportable contract value, cost-to-complete estimate and assessment of recoverability. [2]
Progress may be measured through costs that represent work performed, an assessment of the work, or physical completion. An engineer’s certificate is important evidence, but the billing schedule alone does not determine accounting progress. Materials not yet used and advances to subcontractors for future work should not inflate a cost-based completion percentage.
For a cost-based measure, cumulative revenue equals the eligible costs of work performed to date divided by the latest estimated total contract cost, multiplied by the latest recognised contract revenue. Current-period revenue is that cumulative result less revenue recognised in earlier periods. Revisions to estimates can therefore create a catch-up adjustment in the current period.
Assume a fixed-price contract of 20.00, 16.00 estimated total cost and 4.00 costs of work performed. There are no advances, retentions or recognised losses. Recognition conditions under SKK 8 are met. [2, 5, 7–8]
|
Calculation |
Formula |
Amount or percentage |
|
Completion |
4.00 / 16.00 |
25% |
|
Cumulative earned revenue |
20.00 × 25% |
5.00 |
|
Costs recognised in profit or loss |
Work performed |
4.00 |
|
Accounting gross profit |
5.00 − 4.00 |
1.00 |
|
Net invoices issued |
Assumed billing position |
3.00 |
|
Revenue less net invoices |
5.00 − 3.00 |
2.00 to investigate and reconcile |
|
Entry |
Debit |
Credit |
|
Record and expense work performed |
Construction-service cost 4.00 |
Payables / payroll 4.00 |
|
Recognise earned revenue |
Accrued contract revenue 5.00 |
Construction revenue 5.00 |
|
Record invoices issued |
Trade receivables 3.60 |
Accrued contract revenue 3.00; output VAT 0.60 |
|
Closing balance before corrections |
Accrued contract revenue 2.00; receivables 3.60 |
Output VAT 0.60, before any billing correction |
The 2.00 is not automatically an acceptable unbilled balance. Albania requires monthly invoicing of construction works. If it represents taxable work that should already have been invoiced, correct the invoicing and VAT; a further 2.00 taxable invoice would carry 0.40 VAT. If a legitimate measurement difference remains, document it and present the construction balance under SKK 8. Under IFRS 15, distinguish a contract asset from an unconditional receivable. Input VAT, payments and income-tax adjustments are omitted here.
Assume a two-year contract with a price of ALL 30 million excluding VAT and estimated total costs of ALL 24 million. Costs representing work performed in Year 1 are ALL 9.6 million. Progress is 40%, giving revenue of ALL 12 million and a gross profit of ALL 2.4 million. The table assumes that the monthly works certificates and invoices also total ALL 12 million excluding VAT, with no advances or retentions. This avoids assuming that a statutory invoicing delay is permissible.
|
Year 1 entry |
Debit ALL million |
Credit ALL million |
|
Record project costs |
Work in progress 9.60 |
Payables or payroll liabilities 9.60 |
|
Expense the work performed |
Cost of construction services 9.60 |
Work in progress 9.60 |
|
Recognise earned revenue |
Accrued contract revenue 12.00 |
Construction revenue 12.00 |
|
Record invoices including 20% VAT |
Trade receivables 14.40 |
Accrued contract revenue 12.00 and output VAT 2.40 |
Input VAT and cash settlement are omitted from these entries to keep the example focused. Accrued revenue is a clearing account in this example and has no closing balance because recognised revenue and net billing are equal. The ALL 9.6 million of costs has been released to expense and is not left in inventory as well.
If the contract finishes at the estimated cost and Year 2 net invoices equal Year 2 earned revenue, the complete result is:
|
Measure |
Year 1 |
Year 2 |
Whole contract |
|
Cost of work performed |
9.60 |
14.40 |
24.00 |
|
Cumulative completion |
40% |
100% |
100% |
|
Revenue for the period |
12.00 |
18.00 |
30.00 |
|
Gross profit for the period |
2.40 |
3.60 |
6.00 |
|
Output VAT on assumed invoices |
2.40 |
3.60 |
6.00 |
|
Illustrative tax at 15%, if taxable profit equals the above profit |
0.36 |
0.54 |
0.90 |
|
Year 2 entry |
Debit |
Credit |
|
Record costs |
Work in progress 14.40 |
Payables / payroll 14.40 |
|
Expense completed work |
Cost of construction services 14.40 |
Work in progress 14.40 |
|
Recognise earned revenue |
Accrued contract revenue 18.00 |
Construction revenue 18.00 |
|
Record invoices |
Trade receivables 21.60 |
Accrued contract revenue 18.00; output VAT 3.60 |
The illustrative 15% tax requires the company to be outside any applicable 0% regime, for example because its total annual gross income, including other projects, exceeds 14.00. These are project-level figures, not a complete company tax return.
Where earned revenue and billings legitimately differ, reconcile them by contract. SKK 8 has its own presentation requirements for positive and negative construction balances and invoiced receivables. Under IFRS 15, a contract asset is conditional on something other than the passage of time, whereas a receivable is an unconditional right to payment. An invoice does not by itself resolve that distinction.
Under SKK 8, include variations, claims and incentives only when their specific probability and measurement conditions are met. A claim submitted to the customer is not automatically revenue. Under IFRS 15, apply the rules for contract modifications and variable consideration, including the constraint against a significant revenue reversal. [2, 4]
Two independent situations illustrate why uncertainty and a loss-making contract are different. [2, 5, 10]
|
Uncertain outcome |
Calculation or entry |
Accounting effect |
|
Incurred costs |
Dr construction-service cost 1.00; Cr payables 1.00 |
Full cost of 1.00 is expensed |
|
Recoverable amount |
Dr accrued contract revenue 0.80; Cr construction revenue 0.80 |
Revenue limited to 0.80 |
|
Period result |
0.80 − 1.00 |
Loss of 0.20 |
The expense is 1.00, not only the unrecoverable 0.20. Zero profit arises only when all incurred costs are recoverable. VAT and billing must be assessed separately; the accounting limit is not a VAT exemption. Uncertainty does not authorise a general completed-contract method.
|
Loss-making contract |
Calculation or entry |
Accounting or tax effect |
|
Latest expected revenue / total cost |
20.00 / 22.00 |
Expected total loss 2.00 |
|
Loss already recognised on work performed |
0.60 |
Already included in profit or loss |
|
Additional charge required |
2.00 − 0.60 = 1.40 |
Dr expected-loss expense 1.40; Cr contract-loss provision 1.40 |
|
Total loss after adjustment |
0.60 + 1.40 |
2.00; do not record a further 2.00 provision |
|
Tax reconciliation |
Add back the generally non-deductible provision charge of 1.40 |
If the 0.60 realised loss is otherwise deductible, the project tax result is −0.60 before other adjustments |
The loss example assumes a straightforward remaining obligation, no other impairment and no existing provision. Tax losses are dealt with at entity level; this table does not imply a cash tax refund.
Expected losses require prompt recognition under SKK 8 and SKK 6. Under full IFRS, assess the onerous-contract obligation under IAS 37, including relevant impairment and unavoidable-cost requirements. [2, 10]
A retention generally postpones collection of part of the price rather than reducing earned revenue. Its classification depends on the release conditions. A warranty provision is a separate estimate of expected obligations; it is not the same as the amount the customer retains.
Article 99(5) of the VAT law and Article 20 of Instruction No. 6/2015 require monthly invoicing of construction works, supported by an analytical progress statement, or situacion. VAT is generally 20% of the taxable works value. A contractor cannot defer the tax merely because the customer has not yet paid. [7–8]
The contractor receives an advance of 3.00 plus VAT of 0.60. It subsequently performs and invoices work worth 5.00 plus VAT of 1.00. The whole advance is applied to that work. The entries show the economic effect; the fiscalised documents must identify the advance and prevent duplicate VAT. [7–8]
|
Stage |
Debit |
Credit |
|
Receive and invoice advance |
Bank 3.60 |
Customer advance liability 3.00; output VAT 0.60 |
|
Recognise earned work and gross works billing |
Trade receivable 6.00 |
Construction revenue 5.00; output VAT 1.00 |
|
Apply the invoiced advance |
Customer advance liability 3.00; output VAT adjustment 0.60 |
Trade receivable 3.60 |
|
Collect the remaining amount |
Bank 2.40 |
Trade receivable 2.40 |
|
Cumulative position |
Bank received 6.00; advance and receivable both nil |
Revenue 5.00; net output VAT 1.00 |
The second row assumes earned revenue and the works invoice coincide; otherwise recognise and reconcile them separately. Costs and input VAT are omitted. Revenue at the advance date is zero, but output VAT is 0.60. The later incremental output VAT is 0.40, giving 1.00 overall. Income-tax treatment of the advance must also consider the specific interaction explained below.
An unbilled accounting balance is therefore a reason to investigate the difference. It may reflect a measurement difference, or it may reveal missing monthly invoicing. Describing it as a contract asset does not cure a VAT omission.
At completion of the 30.00 contract, assume all work has been recognised and invoiced with 6.00 VAT. The customer retains 5% of the net contract price (1.50), pays all VAT, and pays the remaining 28.50 net price. No earlier collections are assumed in this standalone illustration. [2, 5, 7–8]
|
Item |
Calculation or entry |
Effect |
|
Total invoiced |
30.00 + 6.00 |
Receivable 36.00 |
|
Cash collected |
28.50 + 6.00 |
Dr bank 34.50; Cr trade receivable 34.50 |
|
Retention outstanding |
30.00 × 5% |
1.50 remains to be collected |
|
Reclassify retention, if appropriate |
Dr retention receivable 1.50; Cr trade receivable 1.50 |
No new revenue or expense |
|
Separate estimated warranty obligation |
Assume a qualifying provision of 0.30 |
Dr warranty expense 0.30; Cr warranty provision 0.30 |
|
Tax effect of creating the provision |
Generally add back 0.30 |
At 15%, current tax is 0.045 higher than if that expense were deductible |
|
Later release and collection of retention |
Dr bank 1.50; Cr retention receivable 1.50 |
No second sale and no second VAT charge on an amount already taxed |
Classification of the retention depends on its conditions: under IFRS 15, a substantive condition beyond the passage of time can require a contract asset instead of a receivable. The 0.30 warranty estimate does not replace or offset the 1.50 retention. Follow actual use and reversal of the provision in the tax reconciliation.
Assume a contract price of 20.00 and initial estimated cost of 16.00. At the next reporting date, an approved variation increases the price to 22.00 and total expected cost to 18.00. Eligible cumulative incurred costs are 9.00; previously recognised revenue was 5.00 and cost was 4.00. The outcome remains reliably estimable under SKK 8. [2]
|
Measure |
Calculation |
Result |
|
Revised completion |
9.00 / 18.00 |
50% |
|
Revised cumulative revenue |
22.00 × 50% |
11.00 |
|
Current-period revenue |
11.00 − 5.00 previously recognised |
6.00 |
|
Current-period cost |
9.00 − 4.00 previously recognised |
5.00 |
|
Current-period gross profit |
6.00 − 5.00 |
1.00 |
|
Cumulative gross profit |
11.00 − 9.00 |
2.00 |
Record Dr accrued contract revenue 6.00 / Cr construction revenue 6.00, and Dr construction-service cost 5.00 / Cr payables or work in progress 5.00, as appropriate. Reconcile invoices and VAT separately. A disputed claim is not included merely because it has been submitted; document the applicable recognition criteria.
Article 45 of Law No. 29/2023 applies to production, installation, construction or service contracts whose duration exceeds, or is expected to exceed, 12 months. It links taxable revenue to the part completed in the relevant year and provides for progress measurement by the statutory cost approach or by the accounting standards. A nine-month contract spanning two calendar years does not meet that duration definition solely because it crosses year-end. [5]
There is an important drafting interaction. Article 3(2)(a) of Decision No. 753/2023 describes contractors’ business income by reference to invoices based on works statements or advances. Accordingly, the proposition that “every advance is irrelevant for income tax until accounting revenue is earned” is too broad. For a contract within Article 45, document how the statutory progress rule is reconciled with that implementing provision. For other arrangements, assess the applicable rule directly. A material disputed advance treatment warrants a written clarification from the tax administration; the financial statements should still follow the applicable accounting standard. [5–6]
Provisions for future contract losses or warranties are generally not deductible when created under Article 50(1)(ë), unless a statutory exception applies. Track their use or reversal so that later tax adjustments do not duplicate a deduction or tax the reversal of a previously disallowed expense. Deferred tax is assessed under SKK 11 or IAS 12; an asset is not automatic merely because an expense was added back. [2, 5]
A business owning land may sell it for cash, exchange it for specified built space, or contribute it to an entity or a jointly controlled arrangement. These transactions have different accounting consequences. A percentage of future units is not necessarily an equity interest or a share of the developer’s profit.
For a cash sale, the seller derecognises the land when the relevant disposal criteria are met and recognises revenue and cost of sales if land trading is its ordinary activity, or the appropriate disposal result for a non-current asset. Its tax computation then follows the business rules and any relevant property-transfer requirements. An individual seller’s personal income-tax calculation should not simply be copied into a company’s corporate tax return.
For a land-for-units exchange, establish which land rights transfer, when they transfer, what the landowner is entitled to receive, and whether the developer has an enforceable delivery obligation. A permit or a preliminary agreement alone does not necessarily establish that an accounting disposal has occurred.
When the recognition conditions are met, the landowner accounts for the land given up and its contractual right to the promised property under the standards applicable to the transaction. Measurement depends on the classification of the land, commercial substance and reliable valuation. A defensible fair-value measure may differ from the land’s previous carrying amount. If exchange conditions for fair-value measurement are not met, a carrying-value basis may be required. The contract percentage alone is not a monetary valuation. [2]
On delivery, classify the received units according to their intended use: inventory for ordinary-course resale, investment property for rental or capital appreciation, or property for own use. Preserve the link between each unit and the land rights surrendered. If the landowner continues to own the land and merely buys construction work, it is also an investor receiving a service, and that service must be analysed accordingly.
Article 2(1) of Decision No. 753/2023 states that an exchange of land for built space under an exchange contract does not trigger the calculation of the property-transfer capital gain at the exchange date for the construction company or the landowner, regardless of status. It places that gain at the subsequent disposal of the property received. This is a specific timing rule, not a general exemption for the project’s profits, construction services or VAT. [6]
The same article links the acquisition value for the later gain calculation to the relevant value of the exchanged land, with rules for documented prior transactions or the applicable land-value map. A business must distinguish the accounting value of the units from their accepted tax basis, and reconcile the exchange treatment with its corporate income-tax position. A fresh accounting valuation does not automatically create an equivalent tax deduction.
Company L exchanges land for 20% of an agreed 2,000 m² deliverable project: 400 m² for L and 1,600 m² for the developer. To isolate the tax-basis issue, assume the exchange qualifies for carrying-value accounting, the land’s carrying amount and accepted tax basis are both 8.00, and the four units received are comparable 100 m² apartments for resale. There are no cash adjustments or additional costs. [2, 6]
|
Event |
Calculation or journal entry |
Meaning |
|
Allocate space |
2,000 m² × 20% |
Four units totalling 400 m² belong to L under the allocation agreement |
|
Recognise the exchange when rights transfer and recognition conditions are met |
Dr right to receive completed units 8.00; Cr land 8.00 |
Land removed; enforceable right recorded |
|
Receive the completed units |
Dr property inventory 8.00; Cr right to receive units 8.00 |
Four units enter inventory |
|
Allocate cost and tax basis |
8.00 / 4 comparable units |
2.00 per unit in this illustration |
|
Sell one unit for 3.00, with recognition criteria met |
Dr receivable 3.00; Cr sales 3.00; Dr cost of sales 2.00; Cr inventory 2.00 |
Accounting profit 1.00; three units remain at 6.00 |
|
Illustrative later taxable gain |
Accepted sale value 3.00 − allocated tax basis 2.00 |
1.00 before other tax adjustments; 15% tax would be 0.15 |
Decision No. 753/2023 defers calculation of the specified property-transfer capital gain to later disposal; it does not dispense with exchange-date accounting. The entries above are conditional on a justified carrying-value basis. If the applicable standard instead requires fair value, record that accounting value, retain the independently established tax basis and assess the resulting tax reconciliation and deferred tax. Do not adopt 8.00 merely to avoid an accounting gain.
For illustration, if properly determined accounting cost were 12.00 but accepted tax basis remained 8.00, cost per comparable unit would be 3.00 in the books and 2.00 for tax. A later sale at 3.00 would produce zero accounting margin and a 1.00 gain on that tax-basis calculation, subject to the treatment of the earlier exchange and other adjustments. This is not an additional 1.00 to tax twice.
The developer records its own rights, costs and supplies under its contract; it does not record L’s subsequent third-party sales as its revenue. The 20% allocation is not, by itself, a cash valuation or an ownership share in the developer.
The VAT law generally exempts qualifying supplies of land and buildings, while taxing construction services. Payment in property rather than cash does not remove the need to identify the supply and its taxable value. A completed-unit exchange, construction on land retained by the owner, and a transfer of development rights should not be assumed to have identical VAT consequences. [7–8]
For the corporate landowner, record separately the land or rights transferred, the property or service received, any cash adjustment and the documents supporting each leg. Where it receives a taxable construction service for use in an exempt property sale or exempt rental activity, the corresponding VAT is generally non-deductible. Where a valid option to tax is relevant, assess its legal conditions before exercising it; neither B2B status nor the words “plus VAT” in a contract are sufficient.
Albanian VAT rules expressly address a company that both builds and owns the development. Article 20 of Instruction No. 6/2015 requires the relevant monthly works statements and self-supply invoices, with the company appearing as supplier and customer. The deduction on the recipient side depends on the intended use of the building. Taxable-use and exempt-use portions must be identified and common works allocated. [8]
Assume eligible external input VAT of 2.00 and a properly established self-supply taxable value of 11.00. There are no other transactions or brought-forward VAT balances. The 11.00 base is an assumption, not a statutory markup. [8]
|
VAT component |
Entire building for exempt sale |
Entire building for qualifying taxable use |
|
Output VAT on self-supply: 11.00 × 20% |
2.20 |
2.20 |
|
Eligible external input VAT |
(2.00) |
(2.00) |
|
Deductible VAT on recipient side of self-supply |
Nil |
(2.20) |
|
Net VAT position |
0.20 payable |
2.00 credit |
|
Financial-reporting consequence |
Non-recoverable self-supply VAT enters eligible development cost |
Recoverable VAT stays outside asset cost |
A VAT credit does not automatically mean an immediate cash refund. Do not record external accounting revenue or an internal profit solely because a self-supply invoice exists.
For financial reporting, a company does not earn profit by supplying itself. Accumulate its actual eligible development costs and non-recoverable taxes. The VAT self-supply value is not, by itself, external revenue or a basis for adding an internal profit to inventory. Separate the fiscalisation entries from their financial-statement presentation.
Where a group uses two separate companies, the contractor does record its sale to the investor in their individual accounts. Related-party pricing rules apply, and consolidation may require elimination of intra-group revenue and unrealised profit. Common ownership does not make the two legal entities a single VAT taxpayer automatically.
For ordinary companies, the standard corporate income-tax rate is 15% under Article 41 of Law No. 29/2023. Article 69 contains a transitional 0% regime for qualifying persons and entities with annual gross income up to ALL 14 million through 31 December 2029. The threshold concerns gross income, not profit. Eligibility, the reporting period and the taxpayer’s status must be checked before applying a rate. [5]
The project file should reconcile accounting revenue, works certificates, invoices, advances and cash receipts. It should also reconcile costs to invoices, payroll, materials records and subcontractor evidence. A fiscalised invoice supports a transaction but does not prove by itself that the service occurred or that the expense is deductible. Work outside the relevant permit conditions can also create VAT deduction problems under the construction instruction. [5, 8]
Local taxes and project obligations need their own schedule. The infrastructure-impact tax falls within the local-tax framework, and its calculation depends on the project’s category and the applicable municipal decision. Property taxes, registration charges and any social-housing obligations should be identified separately. A single national percentage or an assumed tax rate per square metre is not an adequate project budget. Whether a payment enters the asset’s cost depends on its nature and the applicable accounting rules. [11]
For foreign contractors or service providers, check permanent-establishment exposure and withholding tax before payment. Domestic law includes a construction-site duration test, but an applicable tax treaty may change the result. Imported-service VAT is a separate analysis. Contract labels such as “consultancy” or “reimbursement” cannot replace an assessment of the actual supply. [5]
The financial statements also need informative disclosures. For construction contracts, SKK 8 paragraphs 45–46 require disclosure of the revenue-recognition policies, contract revenue recognised, the methods used to determine revenue and completion, and the gross amounts due from and to customers for contract work. Material estimates and provisions should be explained under the relevant standards. [2]
At year-end, the investor should substantiate the cost and recoverability of unsold units. The contractor should support progress, remaining cost and claims. The corporate landowner should support the rights transferred, units receivable and their tax bases. These records allow the financier, auditor and tax inspector to follow the same transaction while applying the rules relevant to their respective work.
Reliable construction reporting starts with identifying what each business owns, supplies and is entitled to receive. Investors need a supported property cost and sales record; contractors need reliable progress and cost-to-complete estimates; corporate landowners need a clear record of the rights exchanged and the units received. Accounting recognition, invoicing, VAT and taxable profit must be reconciled throughout the project.
Use the following checklist at project setup and at each relevant reporting date. Assign a responsible person to each action and retain evidence of completion in the project file.
|
When / responsible business |
Implementation action and evidence |
|
Project setup • All parties |
Identify the contractual role and applicable accounting framework. Retain signed contracts, permits, ownership records and the agreed allocation of units. |
|
Project setup • Investor / landowner |
Classify property for sale, rental or own use. Document the VAT treatment of each intended supply and the basis for recovering or capitalising VAT. |
|
Monthly • All parties |
Maintain separate project ledgers. Reconcile invoices, works statements, materials, payroll, subcontractor costs, advances and cash movements. |
|
Each reporting date • Contractor |
Update contract revenue, approved variations, eligible incurred costs and estimated costs to complete. Recalculate progress and explain changes in margin. |
|
Monthly • Contractor / investor-builder |
Check construction invoicing and any required self-supply. Reconcile VAT on advances and later works invoices to prevent omissions or duplicate taxation. |
|
Each reporting date • Investor |
Allocate development costs consistently across sold, unsold, retained and landowner units. Support the recognition date of each sale and assess inventory recoverability. |
|
Exchange and later disposal • Landowner |
Document when rights transfer and which units are receivable. Keep accounting values and tax bases separately; support the allocation to each unit sold. |
|
Each reporting date • Contractor |
Assess uncertain recoveries, expected contract losses and warranties. Track retention separately and avoid recognising the same loss twice. |
|
Tax close • All parties |
Prepare the book-to-tax reconciliation. Review advances, non-deductible provisions, property reference values, land-cost conditions and the applicable tax rate. |
|
Year-end • All parties |
Review balances and disclosures. Retain reconciliations, valuation evidence and management approvals; document unresolved interpretations and the basis adopted. |
This article is provided for general information only and does not constitute tax, legal or accounting advice. The appropriate treatment depends on the specific facts, contractual arrangements and legislation applicable to each transaction.
Need Expert Advice?
This article was produced by Global Law Experts for general information purposes and does not constitute individual tax or legal advice. The appropriate treatment depends on the specific facts, applicable Albanian legislation and any relevant double tax treaty.
For tailored guidance on investing in Albania, business establishment and Albanian tax compliance, contact Q-Lever. Q-Lever connects foreign investors and businesses with experts in its professional community for tax advisory, accounting and business structuring in Albania.
The references below identify the provisions used, rather than general institutional homepages. Consolidated texts are those made available by the relevant official bodies at the reference date.
[1] Law No. 25/2018 on accounting and financial statements, as amended. Official DPT consolidated text: https://www.tatime.gov.al/shkarko.php?id=14670
[2] KKK, SKK effective 1 January 2025. In particular SKK 4; SKK 5, including paragraph 15; SKK 6; SKK 8, paragraphs 14–17, 22–40 and 43–47; and SKK 11. Official collection: https://kkk.gov.al/standardet-kombetare-te-kontabilitetit-date-efektive-1-janar-2025/
[3] KKK, revised SKK 8 published for comment on 30 September 2026. Consultation status: https://kkk.gov.al/publikime/
[4] IFRS Foundation, IFRS 15 Revenue from Contracts with Customers, particularly paragraphs 35, 50–59 and 105–108; IFRIC March 2018 agenda decision on revenue recognition in a real estate contract. https://www.ifrs.org/issued-standards/list-of-standards/ifrs-15-revenue-from-contracts-with-customers/ and https://www.ifrs.org/news-and-events/updates/ifric/2018/ifric-update-march-2018/
[5] Law No. 29/2023 on income tax, as amended, particularly Articles 5, 41, 43–45, 48–50, 58–59 and 69. https://www.tatime.gov.al/shkarko.php?id=14530. Instruction No. 26 of 8 September 2023, as amended, particularly sections 45, 48–50: https://www.tatime.gov.al/shkarko.php?id=14596. The review also considered Instruction No. 9 of 12 March 2026: https://www.tatime.gov.al/shkarko.php?id=14588
[6] Council of Ministers Decision No. 753 of 20 December 2023, as amended, Articles 2 and 3. The published text repeats paragraph number 3 within Article 3; references here identify the relevant business role. https://www.tatime.gov.al/shkarko.php?id=14466
[7] Law No. 92/2014 on VAT, as amended, particularly Articles 11, 33, 49, 53, 55, 69 and 99. https://www.tatime.gov.al/shkarko.php?id=14534
[8] Instruction No. 6 of 30 January 2015 on VAT, as amended, Article 20 on construction works, self-supply and advances. https://www.tatime.gov.al/shkarko.php?id=14586
[9] IFRS Foundation, IAS 23 Borrowing Costs. https://www.ifrs.org/issued-standards/list-of-standards/ias-23-borrowing-costs/
[10] IFRS Foundation, IAS 37 Provisions, Contingent Liabilities and Contingent Assets. https://www.ifrs.org/issued-standards/list-of-standards/ias-37-provisions-contingent-liabilities-and-contingent-assets/
[11] Law No. 9632/2006 on the local tax system, as amended, including Article 27 on infrastructure impact. Apply the relevant municipal fiscal package to the particular project. Official legislation collection: https://www.tatime.gov.al/c/6/75/taksat-vendore
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