FYR Macedonia: FYR Macedonia – Kazakhstan treaty ratified by parliament

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 – Kazakhstan treaty ratified by parliament

kostovska.jpg

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 (elena.kostovska@eurofast.eu)

Eurofast Global, Skopje Office

Tel: +389 2 2400225

Website: www.eurofast.eu

more across site & shared bottom lb ros

More from across our site

Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum
Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment
CIT base narrowing measures remain more prevalent than increased CIT rates, the report also highlighted
ITR's parent company, LBG, will acquire The Lawyer, a leading news, intelligence and data-driven insight provider for the legal industry, from Centaur Media
KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter
Rishi Joshi, of the Institute of Chartered Accountants of India, warns of potential judicial overreach as assets are recharacterised to bypass a legislative exclusion
Only 2% of in-house survey respondents said they were ‘heavy’ users of AI for TP, Aibidia’s report also found
There was a ‘deeply embedded culture within PwC that routinely disregarded formal confidentiality obligations,’ the chairman of Australia’s Tax Practitioners Board said
Jennifer Best was most recently the acting commissioner of the IRS’s large business and international division
Section 899’s exclusion from the One Big Beautiful Bill does not mean it has been nipped in the bud, Aruna Kalyanam also tells ITR
Gift this article