Disclosure Requirements

Macedonia introduced a requirement to lodge a transfer pricing disclosure report effective 1 January 2019. :

The disclosure report is not required to be filed by a taxpayer: (a) whose total annual revenues do not exceed MKD 300 million, and (b) in respect of transactions between resident persons. Further, taxpayers with annual revenues in excess of MKD 300 million but whose annual transactions with non-resident related parties do not exceed MKD 10 million are only required to file an abridged report.

The submission of the transfer pricing reports with the tax authorities is due by 30 September of the following year.

Effective 1 January 2024, the submission of transfer pricing reports is abolished in order to reduce the administrative burden on both taxpayers and the Public Revenue Office. However, the taxpayers are required to prepare and maintain the transfer pricing report, and it must be submitted at the request of the Public Revenue Office. Further, taxpayers that maintain a transfer pricing report are also required to submit an annexure containing information on the related party transactions along with the annual tax return, within the due date for filing the annual tax return (i.e., 28/29 February after the end of the relevant tax year, extended to 15 March for electronic filing; see Sec.14.3.). The requirement to submit the annexure applies for annual tax returns filed in 2024 for the fiscal year 2023.

Standard Documentation

Short Transfer Pricing Report

The Short Transfer Pricing Report should contain data for each category of transactions (i.e. a group of transactions of the same type) as follows:

Description of the transactions;
Value of the transactions; and
The related entity with which the transactions have been performed.

Full Transfer Pricing Report

In general, the Full Transfer Pricing Report should include a:

Master File;
Local File; and
Statutory-prescribed attachments (e.g. consolidated financial statements of the group, financial statements of the local taxpayer, copy of inter-company agreements, copy of any Advance Pricing Agreements, etc.).

The elements of the Master File and the Local File are aligned with the elements prescribed in the OECD Transfer Pricing Guidelines.

Country-by-Country (CbC) Reporting

Macedonia has till date not introduced a Country-by-Country reporting requirement. However, it has joined the OECD’s Inclusive Framework, membership of which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.

Macedonia has also signed the OECD-Council of Europe Convention on Mutual Administrative Assistance in Tax Matters as amended by the 2010 protocol.

Language of Documentation

The transfer pricing reports are required to be prepared in Macedonian language.

Penalties

Failure to provide the requested documentation may attract a fine ranging from EUR 300 to EUR 10,000.

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