FYR Macedonia: FYR Macedonia ratifies double tax treaty with Bosnia & Herzegovina

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

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

FYR Macedonia: FYR Macedonia ratifies double tax treaty with Bosnia & Herzegovina

kostovska.jpg

Elena Kostovska

On February 3 2014, the FYR Macedonian Parliament has ratified the tax treaty with Bosnia & Herzegovina signed on September 24 2013 in Sarajevo. The ratification law was published in the Official Gazette No. 29 of February 6 2014. Pending ratification of the treaty by Bosnia & Herzegovina and its subsequent entry into force, the agreement provisions will be effective from the following calendar year. The treaty covers the personal income tax, property tax and profit tax in FYR Macedonia and the tax on income of individuals, tax on profit and tax on property in Bosnia & Herzegovina. As usual, the agreement is mostly harmonised with the OECD model with the below specifics that are of interest in the treaty's content.

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 12 months.

As far as withholding taxes are concerned, the treaty with Bosnia & Herzegovina stipulates rates which are slightly higher than what is fairly common in FYR Macedonian double tax treaties; dividends are taxed with 15% (a preferential rate of 5% is applicable when the beneficial owner holds at least 25% of the capital in the dividend-paying company). A standard 10% withholding tax rate on interest has been agreed, which is also applicable to royalties.

In regards to the provisions for the elimination of double taxation, the treaty stipulates that both FYR Macedonia and Bosnia & Herzegovina will allow deduction from taxes in the amount of tax paid to the other state. Bosnia & Herzegovina also reserves the right to take into account any exempted income or capital for which tax has been suffered in FYR Macedonia when calculating the amount of tax payable in Bosnia & Herzegovina for the remaining income/capital.

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

Encompassing everything from international scandals to seismic political events, it’s a privilege to cover the intriguing world of tax
In his newly created role, current SSA commissioner Bisignano will oversee all day-to-day IRS operations; in other news, Ryan has made its second acquisition in two weeks
In the age of borderless commerce, money flows faster than regulation. While digital platforms cross oceans in milliseconds, tax authorities often lag. Indonesia has decided it can wait no longer
The tariffs are disrupting global supply chains and creating a lot of uncertainty, tax expert Miguel Medeiros told ITR’s European Transfer Pricing Forum
Corporate counsel should combine deep technical knowledge with strategic dynamism, says Agarwal, winner of ITR’s EMEA In-house Indirect Tax Leader of the Year award
Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds
Veteran Elizabeth Arrendale will lead the new advisory practice, which will support clients with M&A tax structuring, post-deal integration, and more
MAP cases keep increasing, and cases closed aren’t keeping pace with the number started, the OECD’s Sriram Govind also told an ITR summit
Nobody likes paperwork or paying money, but the assertion that legal accreditation doesn’t offer value to firms and clients alike is false
Ryan hopes the buyout will help it expand into Asia and the Middle East; in other news, three German finance ministers have called for a suspension of pillar two
Gift this article