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Germany - Macedonia Tax Treaty (as amended by 2016 protocol) — Orbitax Tax Hub

Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.


Taxes Covered

(1) This Agreement shall apply to taxes on income and on capital imposed on behalf of the state of a Contracting Party, on the German side also of one of its Länder or one of its political sub-divisions, or local authority thereof, irrespective of the manner in which they are levied.

(2) There shall be regarded as taxes on income and on capital all taxes imposed on total income, on total capital, or on elements of income or of capital, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation.

(3) The existing taxes to which this Agreement shall apply are in particular:

  • (a) on the German side:
    • (i) the income tax (Einkommensteuer),
    • (ii) the corporation tax (Körperschaftsteuer),
    • (iii) the trade tax (Gewerbesteuer) and
    • (iv) the capital tax (Vermögensteuer),
  • including the supplements levied thereon
  • (hereinafter referred to as "German tax");
  • (b) on the Macedonian side:
    • (i) the personal income tax (personalen danok na dohot),
    • (ii) the profit tax (danok na dobivka),
    • (iii) the capital tax (danok na imot)
  • (hereinafter referred to as "Macedonian tax").

(4) The Agreement shall apply also to any identical or substantially similar taxes which are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting Parties shall notify each other of the significant changes that have been made in their respective taxation laws.