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 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

Companies that come to terms with digitised tax processes now will stand to gain from FASTER’s disruption, argues Carlos Silva of Xceptor
Audit specialist Walsh, a 33-year veteran of KPMG, will assume the leadership role in July; in other news, a think tank has claimed that the UK tax advisory market requires ‘urgent reform’
The court emphasised that TP analysis must adhere to the arm's-length principle, be based on the specific facts of each transaction and comply with domestic regulations, one expert says
Singapore extends GST remission in 2025 budget; UK closes in on e-invoicing; two new partners at RSM Belgium ;and more
As we build up to another busy year for the World Tax rankings and ITR Awards, we give a rundown of some of the major firms and trends within the Brazil tax market
Dario Acconci of Hawksford argues that Singapore’s 2025 Budget, which features a hefty corporate income tax rebate, is ‘generous and forward-looking’
The mass firings could affect taxpayer guidance and are expected to reduce the agency’s ability to conduct audits, one expert tells ITR
The law firm, which will operate as an independently managed subsidiary of KPMG, has received court approval with conditions
Krause will take the reins until President Trump’s pick Billy Long assumes the role; in other news, CohnReznick became the latest tax firm to receive private equity backing
Flexibility and transparency on fees ranked favourably against international counterparts, according to new ITR+ research
Gift this article