North Macedonia: Proposed changes to transfer pricing reporting

Proposed amendments to the corporate income tax law

Proposed amendments to the corporate income tax law

Proposed amendments to the corporate income tax law, which would become effective 1 January 2023, include the following changes with respect to transfer pricing reporting:

  • The requirement to submit a transfer pricing report to the tax authorities would be replaced with the obligation to prepare a transfer pricing report to be submitted to the tax authorities upon request.
  • The tax authorities would be allowed to submit such a request after 30 days from the deadline for submission of the corporate income tax return, and the taxpayer would be required to submit the report following such a request within 15 days.
  • Apart from the above, taxpayers would report data on related parties’ transactions as an attachment to their corporate income tax return on a prescribed form.
  • Taxpayers who have the obligation to prepare a transfer pricing report are obliged to keep the report for 10 years.

Read a January 2023 report prepared by the KPMG member firm in North Macedonia


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