FYR Macedonia: FYR Macedonia ratifies double tax treaty with UAE

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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


FYR Macedonia: FYR Macedonia ratifies double tax treaty with UAE

kostovska.jpg

Elena Kostovska

On April 1 2016, the FYR Macedonian parliament ratified the tax treaty signed with the UAE on October 26 2015. The ratification law was published in the Official Gazette No 63 of April 1 2016.

The treaty covers personal income tax and profit tax in FYR Macedonia and income tax and corporate tax in the UAE. The agreement will also be applicable to similar taxes that may be imposed after its signing, provided that the authorities of the signatory parties notify each other about the tax changes introduced.

As usual, the agreement is mostly harmonised with the OECD model, with the below specifics that are of interest.

Permanent establishments are deemed to arise when a building/construction site or an installation project (including any related site activity of supervisory nature) lasts for more than six months. A PE also includes a place of management, a branch, an office, a factory, a workshop or a mine or oil/gas well.

As far as withholding taxes are concerned, dividends are to be taxed at 5%. The same withholding tax rate of 5% on interest and on royalties has been agreed upon.

In regards to the provisions for the elimination of double taxation, the treaty stipulates that both parties will allow deduction from taxes of the amount of tax paid to the other state. Both countries also reserve the right to take into account any exempted income or capital for which tax has been paid in the other country when calculating the amount of tax payable for the remaining income and/or capital.

Pending ratification of the treaty by the UAE and its subsequent entry into force, the agreement provisions will be effective from the calendar year after the year during which it enters into force.

Elena Kostovska (elena.kostovska@eurofast.eu)

Eurofast Global, Skopje Office

Tel: +389 2 2400225

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
More than 200 tier promotions reshaped this year's European rankings as several international firms strengthened their positions in key tax markets
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2026 Asia-Pacific Tax Awards
Monica Erasmus-Koen and her Taxtimbre team will be responsible for building the firm’s TP capability in the competitive Netherlands market
Howden’s Rian Bahia explains how tax insurance can address known risks, unlock transactions and offer an alternative route through disputes and uncertainty
Haynes Boone’s new London partner, Alexandra Ueno-Park, argues that one-size-fits-all policies, billable-hour targets and outdated networking expectations can hold talent back
Death, taxes and Deloitte hoovering up trophies at an ITR awards night. Isn’t that the saying?
AI, pillar two and joint audits could define the next era of tax controversy, says Baker McKenzie tax partner Ariane Calloud
Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims
Gift this article