FYR Macedonia: FYR Macedonia and Israel sign tax treaty
International Tax Review is part of the Delinian Group, Delinian Limited, 4 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

FYR Macedonia: FYR Macedonia and Israel sign tax treaty

Kostovska-Elena

Elena Kostovska

On December 9 2015, FYR Macedonian Government representatives signed a double tax treaty (DTT) with Israeli officials in Jerusalem.

Pending approval from both countries' authorities, the treaty will be effective from the calendar year following the one during which ratifications will take place.

The DTT covers personal income tax and profit tax in FYR Macedonia and income tax, company tax and tax imposed on gains from the alienation of property in Israel. According to the treaty, construction and installation projects exceeding 12 months in duration are considered to constitute a permanent establishment.

Article 10 of the treaty with Israel defines a 5% withholding tax rate for dividends in cases when the beneficial owner holds at least 25% of the dividend-paying company and a 15% tax rate in cases when this participation criterion is not met. The same article clearly defines the withholding tax applied to distributions made by real estate investment companies. Such distributions are subject to 15% withholding tax assuming the beneficial owner's participation of at least 10%. The clarifying remarks of the treaty stipulate that a real estate investment company presumes a company meeting the conditions outlined in section 64A2 of the Israeli Income Tax Ordinance.

Additionally, a standard 10% withholding tax rate is applicable on interest and a 5% rate is applicable on royalties.

As far as prevention of double taxation is concerned, the treaty stipulates that both countries will allow deduction from taxes in the amount of tax paid on it the other state.

Given the recent momentum in the bilateral relations between FYR Macedonia and Israel, including the signing of a bilateral investment protection agreement (IPA) in December 2015, it is expected that swift ratifications of the DTT will ensue during 2016.

Elena Kostovska (elena.kostovska@eurofast.eu), Skopje

Eurofast Global

Tel: +389 2 2400225

Website: www.eurofast.eu

more across site & bottom lb ros

More from across our site

Law firms that pay close attention to their client relationships are more likely to win repeat work, according to a survey of nearly 29,000 in-house counsel
Paul Griggs, the firm’s inbound US senior partner, will reverse a move by the incumbent leader; in other news, RSM has announced its new CEO
The EMEA research period is open until May 31
Luis Coronado suggests companies should embrace technology to assist with TP data reporting, as the ‘big four’ firm unveils a TP survey of over 1,000 professionals
The proposed matrix will help revenue officers track intra-company transactions from multinationals
The full list of finalists has been revealed and the winners will be presented on June 20 at the Metropolitan Club in New York
The ‘big four’ firm has threatened to legally pursue those behind the letter, which has been circulating on social media
The guidelines have been established in the wake of multiple tax scandals and controversies that have rocked the accounting profession
KPMG Netherlands’ former head of assurance also received a permanent bar and $150,000 fine; in other news, asset management firm BlackRock lost a $13.5bn UK tax appeal
The new, fully integrated office will also offer M&A, dispute resolution, IP and corporate tax services
Gift this article