The standard corporate tax rate for companies is 10%. Capital gains are taxed at the same rate as the corporate tax rate i.e., at 10%.

Companies having an annual income of up to MKD 6 million may elect to be taxed under a simplified tax regime. Under the simplified tax regime, companies having annual income up to MKD 3 million are exempt from corporate tax and companies having annual income exceeding MKD 3 million are subject to a lower corporate tax rate of 1%. Once a company opts for this regime and its annual income for the following three years is below the prescribed threshold, then the company is not allowed to change the tax regime.

Certain companies are subject to lower corporate tax rates (see Sec. 10.).

Mineral Royalties

In addition to the regular corporate tax, companies undertaking mining and related activities are liable to pay royalties towards recurring use of sub-surface for exploration purposes. These companies are obliged to pay:

A fee of MKD 60,000 - 120,000 upon obtaining detailed geological explorations depending upon the type of mineral ore; and
An exploitation concession fee, comprised of:

a fee towards the exploited quantities of ore, calculated on a quarterly basis as a specified percentage of the market value of the ore at hand; and
a fixed annual fee, varying from MKD 100,000 - 240,000 depending on the type of ore and per square kilometer of land under concession.

Pillar Two Global Minimum Tax

On 20 December 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) released model rules called Global Anti-Base Erosion (GloBE) rules. These rules basically provide for a co-ordinated system of taxation that is intended to reform international tax rules and ensure that large multinational enterprise (MNE) groups pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.

On 3 January 2025, North Macedonia enacted the Law on Global Minimum Corporate Tax, which implements the OECD/G20 Inclusive Framework’s GloBE rules, including a multinational Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR) as well as a Qualified Domestic Minimum Top-Up Tax (QDMTT). The QDMTT and IIR apply in North Macedonia for financial years commencing on or after 1 January 2024 (i.e., for MNE groups with a consolidated financial statement period beginning on or after 1 January 2024), and the UTPR applies for financial years commencing on or after 1 January 2025.

The Top-up taxes apply to large MNE groups (including constituent entities (CEs) that are members of MNE groups) operating in North Macedonia with consolidated group revenue of EUR 750 million or more in at least two out of the four years immediately preceding the financial year under review. The Top-up tax will apply such that the effective tax rate (ETR) in North Macedonia is 15%.

The ETR is computed by dividing the ‘adjusted covered taxes’ with the ‘net constituent entity income’ of all CEs in North Macedonia. CE’s income or loss for a fiscal year shall be the financial accounting net income or loss with certain adjustments, such as for prior period errors, changes in accounting principles, gains or losses from changes in ownership interest, excluded dividends, and substance-based income exclusion. Further, adjustments are also made to the financial income of CEs in determining CE income or loss to ensure that the outcome of any transactions entered into between CEs of the same MNE groups is at arm’s length (see Sec 13.4.).

Exclusion from IIR and UTPR for Initial Phase of International Activity

An exclusion applies for a period of 5 years from the first fiscal year in which the MNE group entered into the scope of the OECD model rules. The Top-up tax is set at zero, provided all of the following conditions are met:

The MNE group has CEs in not more than 6 jurisdictions (i.e., in North Macedonia and up to 5 other jurisdictions); and
The net book value of tangible assets of all CEs located in all jurisdictions (except the jurisdiction which has the greatest total net book value of tangible assets in the fiscal year in which the MNE group initially falls within the scope of the law) is less than or equal to EUR 50 million.

Safe Harbours

In-scope MNE groups may benefit from certain safe harbours in North Macedonia, whereby the amount of tax due is reduced to zero, provided certain conditions are met. The details of safe harbours, including the conditions to be met, are provided below:

Transitional Country-by-Country Reporting (CbC) Safe Harbours

The transitional CbC safe harbours apply for the fiscal years beginning on or before 31 December 2026 but ending before 1 July 2028. Under the rules, the Top-up tax is set at zero upon application if any one of three tests, all based on the CbC report, is met. The three tests are:

De-minimis test: The total revenue and total profit, as per CbC report, of CEs located in North Macedonia that belong to the same MNE Group for the relevant fiscal year is less than EUR 10 million and EUR 1 million, respectively;
Simplified ETR test: The ETR is equal to or greater than 16% (in 2025), or 17% (in 2026); or
Routine profits test: The MNE group’s profit or loss before income tax, as per CbC report, in North Macedonia, is equal to or less than the substance-based income exclusion amount (SBIE).

Permanent Safe Harbours

An MNE that does not meet the conditions for the Country-by-Country transitional safe harbours, may still be eligible for permanent safe harbours, whereby the Top-up tax is reduced to zero if meeting any of three tests. The main difference with the transitional safe harbours is that the permanent safe harbour tests are determined by reference to the GloBE computation rules, albeit according to simplified calculations, instead of the CbC report. The tests are:

De-minimis Test: The jurisdiction’s average profit is less than EUR 1 million, and the average revenue is below EUR 10 million;
Simplified ETR test: The ETR of the jurisdiction, as determined under the simplified income calculation, is equal to or greater than 15%; or
Routine profits test: The profit or loss before income tax, as determined under the simplified income calculation, is equal to or less than the substance-based income exclusion (SBIE).

Excluded Entities

The following entities are excluded from the scope of the GMT rules:

Government entities, international organizations, non-profit organizations, and pension funds;
Investment funds and real estate investment vehicles but only when they are the ultimate parent entity of an MNE Group; and
Entities directly or indirectly owned by the above-mentioned entities.

Filing of Top-Up Tax Returns

A GloBE information return, along with a QMDTT top-up tax return, must be furnished by the UPE or designated filing entity within 15 months (18 months for the first year of application) from the last day of the reporting fiscal year. The obligation to file is waived if a constituent entity within the MNE group has filed the information return in another jurisdiction provided there exists a competent authority agreement between North Macedonia and that jurisdiction for the automatic exchange of annual information returns. In such cases, the constituent entity located in North Macedonia must notify the tax authorities of the identity of the entity that has filed the information return.

An IIR/UTPR top-up tax return must be filed within 30 days from the deadline for filing the GloBE information return.

Failure to file the top-up tax returns may attract penalties.

Payment of Taxes

The top-up tax payments must be made within 30 days from the deadline for filing the relevant top-up tax returns.

Solidarity Tax

On 25 September 2023, North Macedonia introduced a solidarity tax at the rate of 30% on companies whose total annual income exceeded MKD 615 million in the year 2022. The taxpayer may use any one of the following options, whichever is more favorable, to calculate the standard tax base for the solidarity tax:

The corporate tax base for 2022, minus 1.2 times the average tax base in the years 2018, 2019, and 2020 (i.e., increased by 20%); or
The average corporate tax base for 2021 and 2022, minus 1.2 times the average tax base in 2017, 2018, and 2019.

Taxpayers subject to the solidarity tax were required to determine the amount due using Form DB-DS, which had to be filed by 4 October 2023 (extended from 25 September 2023) through http://etax.ujp.gov.mk. The solidarity tax must be paid within 30 days after the deadline for submitting Form DB-DS.

On 5 February 2025, the Constitutional Court of North Macedonia annulled the Law on the solidarity tax and held it unconstitutional. The Court reasoned that the retroactive application of the tax violates the fundamental principles of the rule of law, legal predictability, and legal certainty. As a result of this decision, taxpayers can claim a refund of the solidarity tax paid within five years of the publication of the Constitutional Court’s decision in the Official Gazette.

Alternative Minimum Tax

There is no minimum tax.

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