North Macedonia Cross-Border Tax Guide 2026

Overview — Cross-Border Taxation in North Macedonia

North Macedonia's cross-border tax rules are governed by the Law on Profit Tax, the Law on Personal Income Tax, and various double tax treaties. The Public Revenue Office (PRO) has been strengthening its international tax capacity, including participation in the OECD's Base Erosion and Profit Shifting (BEPS) Inclusive Framework and the Global Forum on Transparency and Exchange of Information for Tax Purposes. Multinational enterprises operating in North Macedonia must comply with transfer pricing documentation requirements, thin capitalisation rules, and withholding tax obligations. Non-residents earning Macedonian-source income are generally subject to withholding taxes at statutory rates, which may be reduced under applicable treaties.

Transfer Pricing — OECD Guidelines

North Macedonia's transfer pricing rules follow the OECD Transfer Pricing Guidelines. The regulations require that transactions between related parties be priced at arm's length. Related parties include companies under common control, parent-subsidiary relationships, and individuals with significant influence. Documentation requirements include a master file, local file, and country-by-country reporting (for groups with consolidated revenue exceeding EUR 750 million). Acceptable transfer pricing methods include the Comparable Uncontrolled Price (CUP) method, Cost Plus method, Resale Price method, Transactional Net Margin Method (TNMM), and Profit Split method. Advance Pricing Agreements (APAs) are available.

Thin Capitalisation — 4:1 Debt-to-Equity

North Macedonia's thin capitalisation rules limit interest deductions on related-party debt. The maximum allowable debt-to-equity ratio is 4:1. Interest on debt exceeding this ratio is disallowed as a deduction. The rules apply to all related-party debt, including loans from foreign parent companies and sister companies. Interest on third-party (bank) debt is generally not subject to thin capitalisation restrictions. The PRO may also apply general anti-avoidance rules where debt arrangements lack commercial substance.

Withholding Taxes to Non-Residents

Payments to non-residents from Macedonian-source income are subject to withholding tax at the following standard rates (treaty rates may apply):

• Dividends — 10% (reduced to 0-5% under most DTTs)
• Interest — 10% (reduced to 5-10% under most DTTs)
• Royalties — 10% (reduced to 5-10% under most DTTs)
• Management fees — 10%
• Rental income (property) — 10%
• Capital gains (certain assets) — 10%

To claim treaty benefits, the non-resident must provide a Certificate of Tax Residency from their home country. The PRO follows the OECD Model Tax Convention for most of its treaties.

Double Tax Treaties — 50+ Countries

North Macedonia has signed over 50 double tax treaties, making it one of the best-connected jurisdictions in the Balkans. Key treaties provide:

• Dividend rates — 0% for ≥25% shareholding (most EU treaties), 5% for portfolio investments
• Interest rates — 5-10% (many treaties provide 0% for government- guaranteed loans)
• Royalty rates — 5-10%
• Capital gains — many treaties exempt gains on share sales from tax in the source country

The extensive DTT network makes North Macedonia a competitive jurisdiction for holding company structures and regional headquarters.

FAQs

Do I need to register for tax as a non-resident investor?

Non-residents earning Macedonian-source income subject to final withholding tax generally do not need to register. However, a non-resident with a permanent establishment must register and file corporate tax returns.

How do I claim treaty relief?

Submit a Certificate of Tax Residency from your home country to the Macedonian withholding agent or the PRO. The withholding agent will apply the reduced treaty rate. If tax was withheld at the full rate, a refund claim can be submitted to the PRO.

Does North Macedonia have CFC rules?

North Macedonia has introduced controlled foreign company (CFC) rules aligned with the EU Anti-Tax Avoidance Directive (ATAD) standards, attributing certain passive income of a foreign entity to its Macedonian resident shareholders.

Disclaimer

This guide provides general information about North Macedonian cross-border taxation for the 2026 tax year. Tax laws and treaty provisions may change. Always consult with a qualified Macedonian international tax advisor or the Public Revenue Office for advice specific to your situation. InvestmentKit does not provide tax advice.