North Macedonia: Parliament adopts law implementing Pillar Two global minimum tax rules

The Parliament on December 27, 2024, adopted the law on global minimum corporate income tax, introducing the OECD/G20's Pillar Two rules with a minimum tax rate of 15% for multinational companies and large-scale domestic groups with a turnover exceeding €750 million in two of the past four years.

The law aligns with EU Directive 2022/2523 and mandates a minimum effective tax rate of 15% for qualifying groups, enforced through several mechanisms:

• Domestic top-up tax (DMTT): North Macedonian subsidiaries or permanent establishments of foreign groups will pay a top-up tax on excess profits.
• Income inclusion rule (IIR): North Macedonian tax resident ultimate parents of multinational or large-scale domestic groups will compute and pay their share of top-up tax for low-taxed constituent entities.
• Undertaxed payment rule (UTPR): North Macedonian subsidiaries or permanent establishments in multinational groups will incur additional cash tax expenses for their share of top-up tax not charged under the IIR for low-taxed entities.

The law was published in Official Gazette No. 3/2025 and took effect on January 3, 2025. It applies for the fiscal year starting on January 1, 2024, except for the UTPR that will apply as of January 1, 2025.

Read a January 2024 report prepared by the KPMG member firm in North Macedonia