FYR Macedonia: FYR Macedonia and Israel sign tax treaty

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

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

FYR Macedonia: FYR Macedonia and Israel sign tax treaty

Kostovska-Elena

Elena Kostovska

On December 9 2015, FYR Macedonian Government representatives signed a double tax treaty (DTT) with Israeli officials in Jerusalem.

Pending approval from both countries' authorities, the treaty will be effective from the calendar year following the one during which ratifications will take place.

The DTT covers personal income tax and profit tax in FYR Macedonia and income tax, company tax and tax imposed on gains from the alienation of property in Israel. According to the treaty, construction and installation projects exceeding 12 months in duration are considered to constitute a permanent establishment.

Article 10 of the treaty with Israel defines a 5% withholding tax rate for dividends in cases when the beneficial owner holds at least 25% of the dividend-paying company and a 15% tax rate in cases when this participation criterion is not met. The same article clearly defines the withholding tax applied to distributions made by real estate investment companies. Such distributions are subject to 15% withholding tax assuming the beneficial owner's participation of at least 10%. The clarifying remarks of the treaty stipulate that a real estate investment company presumes a company meeting the conditions outlined in section 64A2 of the Israeli Income Tax Ordinance.

Additionally, a standard 10% withholding tax rate is applicable on interest and a 5% rate is applicable on royalties.

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

Given the recent momentum in the bilateral relations between FYR Macedonia and Israel, including the signing of a bilateral investment protection agreement (IPA) in December 2015, it is expected that swift ratifications of the DTT will ensue during 2016.

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

Imposing the tax on virtual assets is a measure that appears to have no legal, economic or statistical basis, one expert told ITR
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
The £7.4m buyout marks MHA’s latest acquisition since listing on the London Stock Exchange earlier this year
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team
A vote to be held in 2026 could create Hogan Lovells Cadwalader, a $3.6bn giant with 3,100 lawyers across the Americas, EMEA and Asia Pacific
Foreign companies operating in Libya face source-based taxation even without a local presence. Multinationals must understand compliance obligations, withholding risks, and treaty relief to avoid costly surprises
Hotel La Tour had argued that VAT should be recoverable as a result of proceeds being used for a taxable business activity
Tax professionals are still going to be needed, but AI will make it easier than starting from zero, EY’s global tax disputes leader Luis Coronado tells ITR
AI and assisting clients with navigating global tax reform contributed to the uptick in turnover, the firm said
Gift this article