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.

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 Global Anit-Base Erosion (GloBE) Rules under Pillar 2 of the Organisation for Economic Co-operation and Development (OECD)/G20 Framework on Base Erosion and Profit Shifting (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 CIT that will impact the largest multinational enterprises (MNEs) present in North Macedonia, provided they meet the statutory criteria. With the domestic top-up CIT, 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 (FY) if their average qualified revenue in North Macedonia is below 10 million euros (EUR) and their average qualified profit is below EUR 1 million. 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.