Page 43 - Central and Eastern European Transfer Pricing Review

Macedonia | 43

Tax treaty/double tax Is there a fling fee for APAs?
resolution Not applicable.

What is the extent of the double tax Does the tax authority publish APA
treaty network? data, either in the form of an annual
Moderate. report or through the disclosure of
data in public forums?
If extensive, is the competent Not applicable.
authority effective in obtaining
double tax relief? Please provide some information
Yes, with respect to the usual application on how successful the APA program
of tax treaties. is and whether there are any known
diffculties?
In regard to avoidance of double taxation Not applicable.
derived from transfer pricing, we have
not witnessed such cases.
Language
When may a taxpayer submit an
adjustment to competent authority? In which language or languages can
documentation be fled?
No formal rules exist.
Macedonian.
May a taxpayer go to competent
authority before paying tax?
No formal rules exist.

Advance pricing
arrangements

What APA options are available, if
any?
No APAs or advance rulings of any kind
exist.

KPMG in Macedonia

Kiril Estatiev
Tel: +389 2 3135 220
Email: kestatiev@kpmg.com

As email addresses and phone numbers change
frequently, please email us at transferpricing@
kpmg.com if you are unable to contact us via the
information noted above.
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