International Tax Review is part of the Delinian Group, Delinian Limited, 8 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 – Kazakhstan treaty ratified by parliament


Elena Kostovska

On February 26 2015, the Kazakhstan Senate approved the double tax treaty signed with FYR Macedonia on July 2 2012. Given that the FYR Macedonian Parliament had already ratified the treaty on December 4 2012 and the ratification was published in the Official Gazette 154 on December 7 2012, it is expected that the treaty will be applicable as of 2016.

The treaty covers personal income tax and profit tax in FYR Macedonia and corporate income tax and the individual income tax in Kazakhstan. Although largely harmonised with the OECD model, certain treaty specifics are discussed below.

Construction sites including the assembly or installation projects and supervisory activities thereof, in duration exceeding six months are, according to the treaty, considered a permanent establishment (PE). The same principle applies to the supply of services (including consulting) in aggregate duration of more than six months within a 12 month period. PEs are also deemed to include installations for the purpose of exploration of natural resources or related supervisory service (including drilling rigs and natural resource exploration ships).

The treaty with Kazakhstan neither deviates significantly from the norm when it comes to withholding tax rates, nor offers any particular tax incentives at least from the FYR Macedonian perspective. Dividends are taxed at the 5% (in cases with minimum 25% capital participation) or 15% rate. A standard 10% withholding tax rate is applicable on interest as well as royalties.

As far as elimination of double taxation avoidance is concerned, the treaty defines that both countries will allow deduction from taxes in the amount of tax paid on it the other state.

Elena Kostovska (

Eurofast Global, Skopje Office

Tel: +389 2 2400225


more across site & bottom lb ros

More from across our site

An intense period of lobbying and persuasion is under way as the UN secretary-general’s report on the future of international tax cooperation begins to take shape. Ralph Cunningham reports.
Fresh details of the European Commission’s state aid case against Amazon emerge, while a pension fund is suing Amgen over its tax dispute with the Internal Revenue Service.
The OECD’s rules may be impossible for businesses to manage, according to tax experts from companies including Shell.
The UK government is now committed to replacing the ‘super-deduction’ with a 100% capital allowances regime to offset the impact of the corporate tax rise to 25%.
Corporate tax is set to rise in the UK for the first time in decades, but the headline rate remains historically low despite what many observers think.
President Joe Biden’s nominee is set to be confirmed as IRS commissioner for a five-year term.
British companies are waiting to hear the details of what will replace the 130% ‘super-deduction’ next week, while Spain considers stopping a major infrastructure company moving to the Netherlands.
President Joe Biden wants to raise corporate tax and impose a higher stock buyback tax on US businesses, but his budget proposal faces insurmountable obstacles in Congress, writes Ralph Cunningham.
EY is still negotiating the terms of the plan to split its audit and consulting functions, but the future of tax services is reportedly a sticking point.
Country-by-country reporting is the best option for safe harbour provisions under the global anti-base erosion rules, according to tax directors at companies including Standard Chartered Bank and Pernod Ricard.