North Macedonia

Corporate - Significant developments

Last reviewed - 03 July 2023

According to the recent amendments to the Corporate Income Tax (CIT) Law, the threshold for submitting mandatory transfer pricing documentation for 2019 was increased from 60 million Macedonian denars (MKD) to MKD 300 million. Taxpayers that have overall annual revenue of up to MKD 300 million do not have the obligation to file transfer pricing documentation. Also, there is no longer an obligation for taxpayers to file transfer pricing documentation for transactions with residents. The deadline for submitting transfer pricing documentation for the calendar year was postponed to 30 September of the following year.

Furthermore, the recent amendments introduced temporary taxation of depreciation calculated at higher rates than the prescribed tax rates. The taxpayer is entitled to a tax credit for the taxed part of depreciation expenses in the tax return for the following year.

According to the latest amendments, the taxation of employees' related expenditures (where applicable) is not linked to their payment.

Also, according to the new amendments in the CIT Law, 10% CIT is payable in case revaluation reserves of tangible and intangible assets are transferred into accumulated profit. The tax base is the transferred amount into accumulated profit less the depreciation of the revaluated value of assets from 1 January 2019 until the date of write-off or disposal of the assets. CIT is payable by way of submitting a specific CIT return by the taxpayer.

A new tax on vehicles was introduced, which is applicable as of 1 January 2020.