FYR Macedonia: FYR Macedonia ratifies double tax treaty with UAE
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 2023

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 & bottom lb ros

More from across our site

Yusuf Akhmadi of Indonesia’s Directorate General of Taxation reports on the country’s latest domestic and cross-border initiatives to clamp down on tax evasion
The new rate is a blow to Samsung, while two law firms have made significant tax hires into their respective Washington DC offices
Rema Serafi, KPMG’s first-ever female vice chair for tax, talks about breaking the mould in an exclusive interview with ITR
The metal multinational’s victory, in a case worth $12 million, continues the trend of companies coming out on top against India’s revenue department
Guy Bud and Matthew Greene from litigation firm Stewarts review a dispute on tiered partnerships, which raises questions on corporation tax and partnership law
The stagnating pay and tax bonuses cap follow slashed payouts for the deals team and business consolidation in the last month
A greater UN role has been secured after disagreements between developed and developing countries over the OECD’s influence in global tax reform
The US-based firm picks up investment fund specialist Ceinwen Rees, while Ireland nearly doubles its corporation tax receipts in three years
The order comes amid controversy over another of David Collard’s companies’ tax and TP affairs
NASSCOM, which represents over 3,000 Indian companies, has argued for the removal of the segmentation rule