North Macedonia

As per the local transfer pricing legislation, the taxpayer whose total annual revenue is above 300 million Macedonian denars (MKD) and the value of its transactions with non-resident related parties exceeds MKD 10 million is required to prepare a Full Transfer Pricing Report, containing a Master File and a Local File.

According to the recent amendments to the Corporate Income Tax (CIT) Law, there is no longer an obligation for companies to submit the transfer pricing documentation for the calendar year by 30 September of the following year. However, the Public Revenue Office has the right to request the transfer pricing documentation no earlier than 30 days after the deadline for submitting of the financial statements and CIT return, which is 15 March. Therefore, the request from the Public Revenue Office can come on 15 April at the earliest for the transfer pricing documentation for the previous year. The taxpayer is required to submit the form within 15 days of receiving the request from the Public Revenue Office. Thus, the earliest potential deadline for submitting the transfer pricing documentation upon request of the tax authorities is 1 May of the following year.

As per the latest amendments to the Law on Value Added Tax (VAT), an obligation is introduced for a foreign person to register for VAT if such person neither has headquarters nor a subsidiary in the country and sells goods and services in the country that are subject to taxation under the VAT Law. These amendments are applicable as of 1 January 2024 onwards.

During 2023, a new Solidarity Tax was introduced, which is applicable only for the current year.

Solidarity Tax is due by the taxpayers that are liable for CIT with generated revenue greater than MKD 615 million for fiscal year (FY) 2022. The generated revenue does not include income from sale of property in bankruptcy proceedings.

The Solidarity Tax rate of 30% should be applied on the tax base determined as a difference between the:

• tax base after deductions for FY 2022 from the annual CIT return or the average base after deductions from FY 2021 and FY 2022, and
• average tax base after deductions from previous periods (FY 2018, FY 2019, and FY 2021) or average tax base after deductions from previous periods (FY 2017, FY 2018, and FY 2019), respectively, increased by 20% (i.e. 30% in case of changes in the taxpayer’s legal status).

Taxpayers are required to submit the tax return for Solidarity Tax no later than 4 October and settle the extraordinary tax until 25 October 2023.

Implementation of Pillar Two minimum taxation rules in North Macedonia

Pillar Two legislation was enacted in North Macedonia on 27 December 2024.

The Law on Minimum Global Corporate Income Tax, is aligned with the GloBE Rules under Pillar 2 of the OECD/G20 Framework (BEPS). This law is set to be implemented retroactively for the tax period starting 1 January 2024.

This landmark legislation introduces a domestic top-up corporate income tax that will impact the largest multinational enterprises (MNEs) present in North Macedonia, provided they meet the statutory criteria. With the domestic top-up corporate income tax, the profit of MNEs generated in North Macedonia will be taxed at a rate of 15%.

MNEs should not be required to pay domestic additional tax for the fiscal year if their average qualified revenue in North Macedonia is below 10 million euros and their average qualified profit is below 1 million euros. This exemption is calculated based on data from the current and the two preceding fiscal years for all companies in the country that are part of the MNE.