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 2026

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 flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Hani Ashkar, after more than 12 years leading PwC in the region, is set to be replaced by Laura Hinton
With the three-year anniversary of the PwC tax scandal approaching, it’s time to take stock of how tax agent regulation looks today
Rolling out the global minimum tax has increased complexity, according to Baker McKenzie; in other news, Donald Trump has announced a 25% tariff on countries doing business with Iran
Among those joining EY is PwC’s former international tax and transfer pricing head
The UK firm made the appointments as it seeks to recruit 160 new partners over the next two years
The network’s tax service line grew more than those for audit and assurance, advisory and legal services over the same period
The deal is a ‘real win’ for US-based multinationals and its announcement is a welcome relief, experts have told ITR
Tom Goldstein, who is now a blogger, is being represented by US law firm Munger, Tolles & Olson
In looking at the impact of taxation, money won't always be all there is to it
Gift this article