FYR Macedonia: Reinstatement of withholding tax on dividends distributed to resident companies

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


FYR Macedonia: Reinstatement of withholding tax on dividends distributed to resident companies

kostovska.jpg

Elena Kostovska

Effective from July 2010 and up until February 2014, the tax treatment of dividends in FYR Macedonia depended on the residency of the dividend-receiving entity/individual. This was because of the fact that in July 2010, the government had introduced an anti-crisis taxation exemption principle, whereby all forms of profit distribution made to resident legal entities were exempt from corporate income tax, effectively eliminating the tax burden on the transfer of profits between resident companies. Profit distributions to non-resident entities and individuals were taxed with a 10% withholding tax rate. However, on January 21 2014 the FYR Macedonian Parliament adopted the proposed amendments to the Law on Profit Tax (published in the Official Gazette no.13 on January 23 2014 and effective as of January 31 2014) which reinstate the final withholding tax of 10% on dividends paid to resident companies. The law effectively levels the field for taxation of all dividend distributions, regardless of the tax residency of the receiving entity or individual.

FYR Macedonian entities paying out dividends are obliged to pay a withholding tax on the dividends distributed to entities or personal income tax on dividends paid to individuals. The same obligation is applied to non-resident entities with a permanent establishment in FYR Macedonia who choose to distribute dividends to other entities.

The tax on dividends is withheld concurrently with the dividend payment (be it monetary or in shares), at a flat rate of 10% regardless of the year for which dividends are distributed. It should be noted that for companies distributing dividends to non-residents, the rate may be reduced under the conditions of a valid double tax treaty, provided that the resident entity distributing dividends explicitly requests a written approval from the Revenue Office which would grant it the right to use the lower or nil tax rate defined in the treaty. If this procedure is not followed, tax will be withheld at the legally prescribed rate, which is 10% and a tax refund would be subsequently requested.

Failure to withhold tax for the payment of dividends is penalised with a fine of €1,500 – €2,500 ($2,000 – $3,500) to the company and a penalty amounting to €500 – €1,000 to the general manager (physical person) of the company.

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

Tax teams must look beyond pillar two’s headline rules as R&D incentives and the US side-by-side deal create new strategic choices for multinationals, says Marta Pankiv of Tricentis
As funds work becomes more complex, Proskauer is betting that embedded tax expertise can strengthen its wider offering
The recently founded AI platform stands out in a crowded marketplace thanks to a compelling vision and friends in the right places
Advisers expect consumption tax reform to stay on course, but debt pressures could push the government towards tougher enforcement and incentive reviews
The firm demonstrated its sweet spot of litigation with an international twist with the recent win for the Danish tax authority…but it’s not a tax case
The recently formed firm has taken a break from hiring EY talent to expand its transactional tax and tax technology capabilities
The AI platform, founded last year by two school friends, is partnering with challenger firms like Unity Advisory and A&M Tax to launch its own assault on the AI tax market
Not only has Aurtus received recognition from ITR in the past, but its founder was both a partner at KPMG and co-founder of Dhruva Advisors
Clients care more about considered counsel than rapid media-friendly soundbites, says Matthew Gilleard, associate director at Infinite
It was also a memorable night for Galicia, KPMG, Skadden and Pinheiro Neto, all of which scooped major awards at a gala ceremony in New York
Gift this article