FYR Macedonia: FYR Macedonia ratifies double tax treaty with Bosnia & Herzegovina

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 ratifies double tax treaty with Bosnia & Herzegovina

kostovska.jpg

Elena Kostovska

On February 3 2014, the FYR Macedonian Parliament has ratified the tax treaty with Bosnia & Herzegovina signed on September 24 2013 in Sarajevo. The ratification law was published in the Official Gazette No. 29 of February 6 2014. Pending ratification of the treaty by Bosnia & Herzegovina and its subsequent entry into force, the agreement provisions will be effective from the following calendar year. The treaty covers the personal income tax, property tax and profit tax in FYR Macedonia and the tax on income of individuals, tax on profit and tax on property in Bosnia & Herzegovina. As usual, the agreement is mostly harmonised with the OECD model with the below specifics that are of interest 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 nature) lasts for more than 12 months.

As far as withholding taxes are concerned, the treaty with Bosnia & Herzegovina stipulates rates which are slightly higher than what is fairly common in FYR Macedonian double tax treaties; dividends are taxed with 15% (a preferential rate of 5% is applicable when the beneficial owner holds at least 25% of the capital in the dividend-paying company). A standard 10% withholding tax rate on interest has been agreed, which is also applicable to royalties.

In regards to the provisions for the elimination of double taxation, the treaty stipulates that both FYR Macedonia and Bosnia & Herzegovina will allow deduction from taxes in the amount of tax paid to the other state. Bosnia & Herzegovina also reserves the right to take into account any exempted income or capital for which tax has been suffered in FYR Macedonia when calculating the amount of tax payable in Bosnia & Herzegovina for the remaining income/capital.

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

Identifying who will bear the costs and concerns around confidentiality are issues yet to be resolved, advisers say
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
The president described it as ‘one of the most important cases in the history of our country’; in other news, Portugal established a VAT group regime
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
Simpson Thacher & Bartlett and MinterEllisonRuddWatts were among the firms that advised on the deal
AI will mean fewer entry-level roles in tax but also the emergence of new jobs, according to tax expert Isabella Barreto
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters
APAs should provide a pragmatic means to agree to an arm's-length outcome for an Australian entity and for the ATO, the tax authority said
Gift this article