Vehicles targeted for tax debts: Tax-Transport Agreement establishes new insurance measures

A new interinstitutional agreement between the General Directorate of Taxes (GDT) and the General Directorate of Road Transport Services (GDRTS) has entered into force with the aim of strengthening fiscal discipline and improving the collection of unpaid tax obligations in Albania.

Under this agreement, the use of vehicles registered in the name of taxpayers with outstanding tax debts will be restricted.

This measure is grounded in Article 89 of Law no. 9920, dated 19.05.2008, “On Tax Procedures in the Republic of Albania,” which grants the tax administration the authority to place a lien or mortgage on a taxpayer’s assets if tax obligations are not settled within the legal deadline.

The securing measure must be issued in writing by the head of the unit responsible for debt collection and is implemented in accordance with the instructions of the minister responsible for finance.

For the first time, this agreement applies the provision specifically to a certain type of asset—vehicles. For many taxpayers, these represent essential tools for daily economic activity and, as such, are considered effective instruments of pressure to encourage the payment of outstanding obligations.

From a legal standpoint, the measure is permitted within the competencies of the tax administration, but it must be accompanied by respect for several fundamental procedural principles, including:

• Prior notification to the taxpayer regarding the debt and the measure to be taken
• The right to administrative or judicial appeal
• Proportionality between the value of the debt and the value of the asset being restricted
• Assessment of the economic impact on the taxpayer’s business activity

However, the implementation of this measure has raised serious concerns about a lack of transparency. The agreement has not been published on the official website of the GDT, creating uncertainty regarding the criteria for application, the procedures followed, and the real possibilities for taxpayers to exercise their legal rights. This situation poses the risk of the measure being perceived as selective, arbitrary, or inconsistent with the principles of the rule of law.

On the other hand, fiscal authorities view the measure as a new tool to promote compliance and increase revenue collection efficiency. Expectations are that the restriction of vehicle use will have an immediate effect, particularly on entities that depend on vehicles for service delivery or logistics.

Nevertheless, the success of this measure will depend heavily on how it is implemented: whether it is enforced in accordance with rule-of-law principles, ensuring a fair process for taxpayers, or whether it risks becoming a coercive mechanism that undermines legal certainty and the economic rights of individuals and businesses.