FYR Macedonia: FYR Macedonia - Azerbaijan treaty enters into force

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 - Azerbaijan treaty enters into force

kostovska-elena.jpg

Elena Kostovska, Eurofast Global

Speedy ratifications of the treaty between FYR Macedonia and Azerbaijan have ensued from both parties recently. The Azerbaijani Parliament ratified the treaty on June 21 2013 while the FYR Macedonian Parliament followed suit just a month later. The ratifications both come shortly after the signing of the treaty which was concluded in April this year.

The treaty covers the personal income tax, property tax and profit tax in FYR Macedonia and the tax on income of physical persons, tax on profit of legal persons, tax on property and land tax in Azerbaijan. As usual the treaty is mostly harmonised with the OECD model with the below specifics that can be observed 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 or consulting nature) lasts for more than 12 months.

As far as withholding taxes are concerned, the treaty stipulates rates which slightly deviate from what FYR Macedonian treaties usually define; dividends are taxed at 8% (no preferential rate related to a minimum capital participation has been prescribed). The same 8% withholding tax rate on interest has been agreed on, which is also applicable to royalties.

Income from employment, pensions, and artists/sportsmen income articles of the treaty are fully harmonised with the OECD model treaty.

In regards to the provisions about elimination of double taxation, the treaty stipulates that both FYR Macedonia and Azerbaijan will allow deduction from taxes in the amount of tax paid on it on the other state.

The treaty has entered into force on July 30 2013 (Official Gazette No.107) and will be applicable for all types of affected taxes in both countries as of January 1 2014.

Elena Kostovska (elena.kostovska@eurofast.eu)

Eurofast Global, Skopje Office, FYR Macedonia

Tel: +389 2 2400225

Website: www.eurofast.eu

more across site & bottom lb ros

More from across our site

US partner Matthew Chen was named as potentially the first overseas PwC staffer implicated in the tax leaks scandal, in a dramatic week for the ‘big four’ firm
PwC alleged it has suffered identifiable loss and damage arising out of a former partner's unauthorised use of confidential information; in other news, Forvis Mazars unveiled its next UK CEO
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
Gift this article