FYR Macedonia: FYR Macedonia – Kazakhstan treaty ratified by parliament

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

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 & bottom lb ros

More from across our site

Luxembourg saw the highest increase in tax-to-GDP ratio out of OECD countries in 2023, according to the organisation’s new Revenue Statistics report
Ryan’s VAT practice leader for Europe tells ITR about promoting kindness, playing the violincello and why tax being boring is a ‘ridiculous’ idea
Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems
A high number of granted APAs demonstrates the Italian tax authorities' commitment to resolving TP issues proactively, experts say
Malta risks ceding tax revenues to jurisdictions that adopt the global minimum tax sooner, the IMF said
The UK and what has been dubbed its ‘second empire’ have been found to be responsible for 26% of all countries’ tax losses by the Tax Justice Network
Ireland offers more than just its competitive corporate tax environment but a reduction in the US rate under a Trump administration could affect the country, experts tell ITR
The ‘big four’ firm was originally prohibited from tendering for government work until December 1 due to its tax leaks scandal, but ongoing investigations into the matter have seen the date extended
Approximately 74% of MAP cases in 2023 reached a full resolution, but new transfer pricing MAP cases fell by 16%
Brazil is looking to impose the OECD’s 15% global minimum tax on multinationals; in other news, PwC is set to pull out of Fiji
Gift this article