Last year, Iute in Albania paid 1.1 billion lek or 11.4 million euros in expenses for her mother in Estori.
Data from the company's official balance sheet shows that 605.5 million lek was paid for management services by the parent, 219 million lek were guarantee services, while the remaining 274.3 million lek are interests that Iute in Albania pays to the Estonian owner as debt interest.
In an ideal tax system, where capital is taxed the same across borders, a company's transactions with related parties would pose no problem. But in the real world, there is a problem. Tax rates vary from country to country. In Albania, the corporate tax rate is 15 percent. But in Estonia, it is zero.
This loophole, otherwise known as tax arbitrage, allows a company to move its profits through related party transactions from countries where they are taxed to countries where the tax is zero. This is what Iute appears to be doing in Albania.
Historical data shows that in the last five years, the expenses that Iute Albania makes for her mother in Estonia have almost tripled from 3.96 million euros in 2020, to 11.4 million euros last year.

Legally, a company is free to contract services from anyone, including its parent or group companies. But the question that arises is whether these expenses are for real services, based on market costs, or are they artificially inflated to reduce profits in Albania, where they are taxed at 15 percent, and transfer them to Estonia, where they are taxed at zero.
Contracting out management services for 6.3 million euros per year seems like a red flag. Moreover, balance sheet data shows that this item has grown at an extraordinary pace in the last 5 years, from 184 million lek in 2020 to 605 million lek last year.

When you add up only the management and guarantee services, it turns out that 824 million Lekë (approximately 8.5 million euros) were transferred directly to Estonia as operating expenses.
This value is twice as large as the entire net profit that the company left in Albania (421 million Lekë). Through this method, the company reduces the profit in Albania and the taxes it must pay, even though this is income earned in Albania.
Legally, the Tax Authorities have the right to scrutinize companies' transactions with related parties for tax avoidance purposes. But the money trend that Iute leads to her mother seems, at best, suspicious. A red flag that should alert the Tax Authorities./ Kapital