Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

North Macedonia (Republic of)

Recent developments relating to MAP in North Macedonia prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• No developments were reported

Other developments relating to MAP

• No developments were reported

Latest Action 14 Peer Review report

The stage 1 Simplified Peer Review report of North Macedonia is expected to be published early 2024.

Tax treaty network of North Macedonia

• 50 treaties, applicable to 50 jurisdictions (covering all treaties signed, although not necessarily in force)

• status of MLI: signed.

Table 1. State of play of North Macedonia's tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
46	0	4

Source: OECD

North Macedonia's MAP programme

Organisation of competent authority function

• six persons:

  • one head of unit

  • four persons working on MAP cases.

• contact persons for MAP requests:

  • Public Revenue Office General Directorate Blvd. Kuzman Josifovski Pitu no. 1, 1000 Skopje, Republic of North Macedonia Tel: [phone] 00389 76 445 471 e-mail: [e-mail].

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	No MAP guidance published
MAP profile	23 May 2023	https://www.oecd.org/tax/dispute/north-macedonia-dispute-resolution-profile.pdf

Overview of North Macedonia's MAP Statistics for 2022

Please refer to https://www.oecd.org/tax/dispute/map-statistics-north-macedonia.pdf for details with respect to North Macedonia's MAP Statistics.

Cases closed in 2022

No MAP cases were closed by North Macedonia in 2022.

Figure 2. Evolution of North Macedonia's MAP caseload (2016-22)

Source: OECD

Table 3. Overview of North Macedonia’s MAP caseload for 2022

Inventory for year 2022	Opening Inventory 1/1/2022	Cases started	Cases Closed	End Inventory 31/12/2022
Attribution/allocation cases	0	0	0	0
Other cases	1	0	0	1
Total	1	0	0	1

Source: OECD

Table 4. North Macedonia’s average time to resolve MAP cases in 2022

Cases resolved in year 2022	Pre-2016 cases		Post-2015 cases		All
	Number of cases	Average time	Number of cases	Average time	Number of cases	Average time
				Start to End
Attribution / Allocation cases	0	N/A	0	N/A	0	N/A
Other cases	0	N/A	0	N/A	0	N/A
All cases	0	N/A	0	N/A	0	N/A

Source: OECD