North Macedonia: VAT law amendments; new guidance on Pillar Two top-up tax
Preferential 5% VAT rate for residential buildings and apartments extended to December 31, 2028.
The following amendments to the value added tax (VAT) law were enacted:
- The VAT exemption for imports of small value shipments was amended to apply only to small shipments of non-commercial nature sent from one individual to another—effective December 18, 2025. The threshold value remains the same (€22), and as previously, the exemption does not apply for alcohol and alcoholic beverages, perfumes, tobacco, and tobacco products.
- The preferential 5% VAT rate for residential buildings and apartments was extended to December 31, 2028.
In addition, a new rulebook on calculation and payment of the Pillar Two top-up tax was published in official gazette No. 270 (dated December 31, 2025). The rulebook specifically refers to the OECD models and prescribes the forms for qualified domestic minimum top-up tax (QDMTT), the income inclusion rule (IIR), and the undertaxed profit rule (UTPR).
Read a January 2026 report prepared by the KPMG member firm in North Macedonia