FYR Macedonia: FYR Macedonia - Azerbaijan treaty enters into force

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 - Azerbaijan treaty enters into force

kostovska-elena.jpg

Elena Kostovska, Eurofast Global

Speedy ratifications of the treaty between FYR Macedonia and Azerbaijan have ensued from both parties recently. The Azerbaijani Parliament ratified the treaty on June 21 2013 while the FYR Macedonian Parliament followed suit just a month later. The ratifications both come shortly after the signing of the treaty which was concluded in April this year.

The treaty covers the personal income tax, property tax and profit tax in FYR Macedonia and the tax on income of physical persons, tax on profit of legal persons, tax on property and land tax in Azerbaijan. As usual the treaty is mostly harmonised with the OECD model with the below specifics that can be observed 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 or consulting nature) lasts for more than 12 months.

As far as withholding taxes are concerned, the treaty stipulates rates which slightly deviate from what FYR Macedonian treaties usually define; dividends are taxed at 8% (no preferential rate related to a minimum capital participation has been prescribed). The same 8% withholding tax rate on interest has been agreed on, which is also applicable to royalties.

Income from employment, pensions, and artists/sportsmen income articles of the treaty are fully harmonised with the OECD model treaty.

In regards to the provisions about elimination of double taxation, the treaty stipulates that both FYR Macedonia and Azerbaijan will allow deduction from taxes in the amount of tax paid on it on the other state.

The treaty has entered into force on July 30 2013 (Official Gazette No.107) and will be applicable for all types of affected taxes in both countries as of January 1 2014.

Elena Kostovska (elena.kostovska@eurofast.eu)

Eurofast Global, Skopje Office, FYR Macedonia

Tel: +389 2 2400225

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The tax technology company will be providing a free demonstration of its OTP software and offering best practice advice on whether to ‘buy or build’ on September 8
Johanes Glorinus Saragih of Indonesia’s Directorate General of Taxes outlines the nation’s delicate geopolitical situation, as it sits between a rock and a hard place with the US and pillar two
The law firm’s head of tax, trade and wealth management likens tax legislation to a complex puzzle, recommends a sturdy coffee mug, and explains why acronyms make tax cool
The global tax and accounting firm has appointed two experienced TP advisers from a New Jersey-based boutique
A lack of commitment from major jurisdictions and the associated compliance burden are obstacles facing the OECD initiative
Richard Gregg is no longer fit and proper to be a tax agent, said the TPB; in other news, MHA completed its acquisition of Baker Tilly South-East Europe
Recent Indian case law emphasises the importance of economic substance over mere legal form in evaluating tax implications, say authors from Khaitan & Co
PepsiCo was represented by PwC, while the ATO was advised by MinterEllison, an Australian-headquartered law firm
Three tax experts dissect the impact of a 30% tariff that has shaken up trade relations between South Africa and the US
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Americas Tax Awards
Gift this article