Page 42 - CEE Tax Guide 2025

North Macedonia

Forvis Mazars N-P-KONSALTING
DOO Skopje
Street Dame Gruev num. 7,
1000 Skopje
Phone: +389 (0)2 3166 144
www.forvismazars.com/mk

Corporate taxes and other direct taxes tax base is reduced by the amount of the investment
of profits (reinvested profit) for development
There is a 10% flat general corporate income tax rate purposes, i.e. investments in tangible assets
for all taxpayers in North Macedonia. Exceptionally, (property, plant, and equipment) and intangible
companies with a total revenue of up to 3 million assets (computer software and patents) intended
denars (MKD) are exempt from the payment of CIT, to expand the activity of the taxpayer.
and companies with a total revenue between North Macedonia applies thin capitalization (3:1).
3,000,001 and 6,000,000 denars have the option Thin capitalization rules also apply to loans from
to pay CIT at 1% of their total revenue. banks if they are granted in relation to a deposit
The tax base is the pre-tax profit modified by several of the shareholder in that particular bank. Also, thin
increasing and decreasing items. Losses can capitalization rules do not apply for newly established
be carried forward within a limited period of 3 years. companies for the first three years of their operation.
Losses cannot be carried back. No special limitations In North Macedonia, there is a withholding tax
are applicable in the case of M&A transactions. The
at a rate of 10% on dividends, interests, royalties,
and other incomes paid by a North Macedonian
Transfer pricing in North Macedonia company to a foreign company. The entities obliged
to pay withholding tax should submit a Report on the
Arm’s length principle Since 2019
withholding tax paid on the form “DD-I” to the Public
Documentation liability The CIT payer has Revenue Office once a year.
to prepare a TP report and
keep it in its records. In North Macedonia, there is a withholding tax
at a rate of 10% on dividends, interests, royalties,
APA No The tax legislation does and other incomes paid by a North Macedonian
not provide a binding APA.
company to a foreign company. The entities obliged
Country-by-Country No No obligation regarding to pay withholding tax should submit a report on the
liability Country-by-Country
reporting as yet. withholding tax paid on the form “DD-I” to the
Public Revenue Office once a year. This form must
Master file-local file No The report has to contain: be submitted by February 15 of the following year.
(OECD BEPS 13) Master File, Local File
applicable and attachments. North Macedonia has a wide international treaty
(DTT) network with 50 double tax treaties, and the
Penalty
withholding tax rate can be reduced or abolished
lack of documentation ~ EUR 2,500—3,000 / under the active DTT. Taxpayers are obliged to obtain
missing document approval from the Macedonian tax authorities prior

tax shortage Up to 10 times to applying the tax rates from DTT.
the amount of the The tax rate on sales and other transfers of real
understatement of tax.
estate and rights to real estate is 2% to 4% of the
Related parties 20% < Entities (control, market value of the property. There is also a property
significant inf.), family,
members of Board, tax (the rate is 0.1%-0.2%) paid annually by owners
foreign entities. of immovable properties.
Safe harbors Interest from the
loans as EURIBOR+1% VAT and other indirect taxes
(SKIBOR+1% for loans
extended in MKD). The general rate is 18%; a reduced rate of 5%
is applicable for food products, pharmaceuticals,
Level of attention paid 7/10
by Tax Authority production equipment, computers, and public

Central and Eastern European tax guide 2025 Forvis Mazars 42