Macedonia: Double tax treaty between FYR Macedonia and Belgium 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 2026

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


Macedonia: Double tax treaty between FYR Macedonia and Belgium enters into force

intl-updates-small.jpg

Following a very long ratification process, the 2010-dated agreement for the avoidance of double taxation (DTA) concluded between FYR Macedonia and Belgium finally entered into force on July 17 2017.

The treaty, generally applicable from January 1 2018, replaces the old treaty signed between former Yugoslavia and Belgium in 1980.

The DTA defines maximum withholding tax rates of 15% on dividends (or 5% if the beneficial owner holds directly at least 10% of the dividend-paying company or 0% if the beneficial owner holds at least 25% of the dividend-paying company for an uninterrupted period of 12 months), whereas interest is taxed at the Macedonian statutory rate of 10%, as are royalties. The term "royalties" is deemed to also include films or tapes used for TV or radio broadcasting as well as the use or right to use scientific, industrial or commercial equipment.

It is worth noting that the reduced dividends' withholding rates of 5% and 0% are lower than the ones previously prescribed (previously 10% under the condition of 25% participation).

The treaty's limitation of benefits clause states that no reduction or exemption is applicable to income related to artificial arrangements, i.e. arrangements that meet no legitimate financial or economic needs, nor have valid economic reasons. In terms of the method of double taxation avoidance, both countries generally use the credit and exemption-with-progression method.

kostovska.jpg

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

Eurofast Global

Tel: +389 2 2400225

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

The big four firm is rightfully prioritising transparency and accountability as it seeks to rebuild from its scandal, but a glaring structural issue remains
A recent hiring flurry has taken the firm’s number of partner appointments this year to 121 and put it on track to hit 160 partner target early
The move brings specialist tax and litigation capability to EY as it seeks to close the gap on Baker McKenzie and Venezuela’s leading local firms
The industry’s response to AI requires an unfamiliar ingredient as firms battle to shape their futures
The ambitious big four challenger firm has also appointed ex-RSM partner Brad Ashton to build out its customs and global trade practice
The big four firm allegedly reviewed backdated documents and signed off on accounts that removed hundreds of millions of dollars of Abramovich’s assets
New Tier 1 entrants and an expanding cohort of established players indicate that law firms are becoming increasingly credible challengers in Europe's TP market
Awards
Leading firms and individuals gathered in Dubai to celebrate standout legal, dealmaking and tax work across the region
Tax authorities want more revenue, have better tools to find it and are increasingly willing to fight for it
Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
Gift this article