North Macedonia became the 117th member to join the Inclusive
Framework ("IF") for the global implementation of the
Base Erosion and Profit Shifting (BEPS) Project in August 2018.
Under this framework, North Macedonia was committed to implement
Action 5, Action 6, Action 13, and Action 14.
Even though the country adopted new TP rules and an analytical
TP Rulebook aligned with documentation requirements as those
described in Action 13 Transfer Pricing Documentation and CBCR,
CBCR is not yet an obligation in the Republic of North
Macedonia.
Who is affected?
Taxpayers with an annual Turnover
exceeding revenues 300 Million MKD (almost 4.9 M Euro) are obliged
to prepare and submit either a simplified TP report or full
documentation depending on the volume of their intra-group
transactions. Taxpayers exceeding the above threshold and at the
same time are engaged in intra-group
transactions with non-resident related parties in
annual amount of up to MKD 10 million
