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: Kazakhstan treaty ratified by Parliament


Elena Kostovska

On December 4 2012, the FYR Macedonian Parliament ratified the income tax treaty signed with Kazakhstan. The ratification was published in the Official Gazette 154 on December 7 2012. The treaty, initially signed between the two countries on July 2 2012, covers the personal income tax and profit tax in FYR Macedonia and the corporate income tax and the individual income tax in Kazakhstan. As is usually the case, the treaty is mostly harmonised with the OECD model; however, certain specifics can be noted.

Building/construction sites as well as assembly or installation projects (including any related site activity of supervisory nature) lasting for more than six months will, according to the treaty, imply a permanent establishment (PE). Services, including consulting, provided via employees and related parties, in aggregate duration in excess of six months within a 12 month period are also considered PEs.

PEs are, in addition to the standard classifications, also deemed to include installations/structures for exploration of natural resources or related supervisory service, drilling rigs and natural resources exploration ships.

As far as withholding taxes are concerned, the treaty with Kazakhstan does not deviate significantly from the norm or offer any particular tax incentives at least from the FYR Macedonian perspective; dividends are taxed at the 5% or 15% rate (the preferential rate being applicable in cases with a minimum 25% capital participation). A standard 10% withholding tax rate on interest has been agreed on and the same rate is applicable to royalties.

Employment, pensions, and artists/sportsmen income articles of the treaty are fully harmonised with the OECD convention.

Regarding the elimination of double taxation, the treaty stipulates that both countries will allow deduction from taxes in the amount of tax paid on it in the other state.

Pending Kazakhstan's ratification, the treaty will enter into force as soon as the ratification is completed and will be applicable as of the beginning of the calendar year following the year of entry into force.

Elena Kostovska (

Eurofast Global, Skopje Office, FYR Macedonia

Tel: +389 2 2400225


more across site & bottom lb ros

More from across our site

Governments now have the final OECD guidance on how to implement the 15% global minimum corporate tax rate.
The Indian company, which is contesting the bill, has a family connection to UK Prime Minister Rishi Sunak – whose government has just been hit by a tax scandal.
Developments included calls for tax reform in Malaysia and the US, concerns about the level of the VAT threshold in the UK, Ukraine’s preparations for EU accession, and more.
A steady stream of countries has announced steps towards implementing pillar two, but Korea has got there first. Ralph Cunningham finds out what tax executives should do next.
The BEPS Monitoring Group has found a rare point of agreement with business bodies advocating an EU-wide one-stop-shop for compliance under BEFIT.
Former PwC partner Peter-John Collins has been banned from serving as a tax agent in Australia, while Brazil reports its best-ever year of tax collection on record.
Industry groups are concerned about the shift away from the ALP towards formulary apportionment as part of a common consolidated corporate tax base across the EU.
The former tax official in Italy will take up her post in April.
With marked economic disruption matched by a frenetic rate of regulatory upheaval, ITR partnered with Asia’s leading legal minds to navigate the continent’s growing complexity.
Lawmakers seem more reticent than ever to make ambitious tax proposals since the disastrous ‘mini-budget’ last September, but the country needs serious change.