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

Over two-thirds of survey respondents back the continuation of the UK’s digital services tax, research commissioned by the Fair Tax Foundation also found
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
Gift this article