Transfer pricing in Macedonia at a glance
|Regulation Type||National regulations|
|Are there specific transfer pricing regulations?||Yes|
|Submission deadline upon request||N/A|
|Annual update required||N/A|
|Official language requirements||N/A|
|Potential impact of penalties||EUR 2,500 – EUR 3,000 or/and suspense of business activities for 3 to 30 days|
Macedonian tax law
Rules for transfer pricing in Macedonia are based upon:
- Corporate Income Tax Law articles 13, 14 and 16
- Tax procedures Law article 60
- Customs Law article 28
- Administrative guideline 135/2011
- Administrative guideline 39/2005
The Macedonian transfer pricing rules make no reference to the OECD Transfer Pricing Guidelines or to the OECD in any other matter.
Accepted methods are:
- Comparable Uncontrolled Price (CUP) Method
- Cost plus method
Priority of methods
Rules for transfer pricing in Macedonia prefer the CUP method of the Cost Plus method.
Information that should be included in the documentation:
Rules for transfer pricing in Macedonia don’t provide for specific documentation requirements in regard to deadlines and languages.
Submission deadline upon request by tax authorities
There is no specific deadline; a deadline is given to the taxpayer when the taxpayer is requested to submit the transfer pricing documentation. Generally the term to submit the documentation is very short.
Advance Pricing Agreements
Rules for transfer pricing in Macedonia do not provide for an option to obtain for an Advance Pricing Agreement.
Failing to comply with the Macedonian documentation requirements could result in a fine from EUR 2,500 to EUR 3,000 or/and suspense of business activities for 3 to 30 days.