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.