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Company Formation Macedonia



Double Tax Treaties in Macedonia

Updated on Tuesday 31st July 2018

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double-tax-treaties.jpgMacedonia has signed several double taxation agreements with countries worldwide and continues to develop the business and economic relations with other states too. A recent double tax agreement was signed with Belgium and entered into force this year in January. Avoiding the double taxation of profits in Macedonia is the main aspect of such an arrangement and ensures that businesses are properly placed on the market. Our company formation representatives in Macedonia can offer foreigners the needed support at the time of company incorporation in Macedonia and can also provide tax advice on request.

The countries which signed double tax treaties with Macedonia

The Republic of Macedonia signed 33 double taxation agreements with the following countries: Albania, Egypt, Austria, Belarus, Bulgaria, Belgium, Netherlands, Croatia, Czech Republic, Denmark, Italy, Iran, Latvia, Germany, France, Serbia and Montenegro, Hungary, Moldova, China, Poland, Romania, Russian Federation, Slovenia, China, Switzerland, United Kingdom, Sweden, Turkey, Ukraine, Qatar, Finland, Spain, Lithuania.
Likewise, Macedonia entered into several Free Trade Agreements with countries like Liechtenstein, Switzerland, Iceland, Norway, Serbia, Montenegro, Kosovo, Albania, Bosnia and Herzegovina. The Macedonian authorities are currently developing the investment protection treaties which involve a wide range of countries for which the business matters are mandatory. In certain cases, these are the same countries for which a double taxation treaty has been signed. Such agreements intend to protect the foreign investors and their assets on the Macedonian market.

The main provisions of tax treaties signed by Macedonia

The double taxation agreements in Macedonia regulate the taxation of incomes, dividends, interests, capital, and royalties for foreign companies with establishments in this country, and mention the conditions through which these provisions are applied. The following information is important to foreign investors in Macedonia:
  • the withholding taxes are lower for a signatory country, and in particular circumstances, it is not imposed on interests, royalties, and dividends.
  • the withholding tax is set at 10% or lower, depending if the company has non-resident shareholders from a state which signed a tax treaty with Macedonia;
  • in some cases, the withholding tax may involve a 15% rate;
  • if such provisions are not mentioned in a treaty, a Tax Exchange Information Agreement can be signed.

Who can benefit from the double tax treaties signed with Macedonia

All investors with origins from the above-mentioned countries who would like to set up a company in Macedonia, regardless of the type of business, can take advantage from the provisions of the double taxation agreements signed by Macedonia. The main condition is to have company establishments in this country as a foreign investor.

What is a permanent establishment?

Any office, branch, workshop, factory or building considered a fixed place for business in Macedonia is called a permanent establishment. In other words, your business office or any related property through which the activities are carried can be considered permanent establishments. We remind that the Articles of Association comprise information about the business address of your firm in Macedonia.

Do natural persons benefit from DDTs?

Yes, individuals living and working in Macedonia are exempt from a double taxation on their registered revenues. Our team of company formation consultants in Macedonia can provide you with complete information about this matter.


The OECD model tax convention

The double taxation agreements signed by Macedonia follow the OECD model tax convention. OECD or the Organization for Economic Cooperation and Development oversees the economic and business activities of countries worldwide. To take full advantages of the double tax conventions and their endowments, the foreign taxpayers need to offer a binding proof that the taxes are already paid in the home country. In this sense, a valid certificate of a taxpayer is normally issued by the foreign tax authorities and then registered with the financial authorities in Macedonia.
If you want to establish your business presence on the Macedonian market and if you want to know more about the taxation structure before registering a company in Macedonia, we suggest you contact our company incorporation agents in Macedonia.


Meet us in Skopje

Call us now at +381605001680 to set up an appointment with our lawyers in Skopje, Macedonia. Alternatively you can incorporate your company without traveling to Macedonia.

As a Balkanski Centar Group client, you will benefit from the joint expertize of local lawyers and international consultants. Together we will be able to offer you the specialized help you require for your business start-up in Macedonia.

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The team from CompanyFormationMacedonia.com is very qualified and benefits from extensive expertise in this area. I would definitely recommend them to any entrepreneur decided to start his own business here.

Mihai Cuc, Partner of
Enescu&Cuc; Law Firm

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