Republic of North Macedonia Transfer Pricing Documentation Requirements

Scope of the documentation obligation

North Macedonia structures its documentation as a report rather than separate standalone files. A local taxpayer with revenue above MKD 300 million, approximately EUR 4.8 million, that has related-party transactions with non-resident entities exceeding MKD 10 million may be obliged to submit the full transfer pricing report, comprising the Master File, the Local File, and appendices. Taxpayers below those thresholds submit a short-form report instead. The documentation is prepared in Macedonian and its Cyrillic alphabet. There is no Country-by-Country reporting obligation in the regime as captured.

Distinctive features of the regime

The defining feature of the regime is the full-versus-short-form structure, under which the Master File and Local File are components of a single full report required above the revenue and transaction thresholds, while a lighter short-form report covers lower levels of related-party dealings. The penalty is geared to the size of the taxpayer, reaching up to EUR 10,000 for late submission of the full or short-form report, with the responsible person liable for up to EUR 500, and there is no separate penalty for the Local File alone. A safe harbour applies to intercompany financing, under which a rate within one percentage point of the relevant reference rate is treated as arm’s length.

Benchmarking and comparables

The benchmarking analysis should start from North Macedonia, expanding to countries with similar market conditions only where no local comparables can be identified. There is no specific requirement on single-year versus multi-year analysis, although a taxpayer using multi-year data should disclose the reason. There are no specific requirements on the frequency of a fresh search, with practice aligned to the OECD Guidelines. The limitation period is five years, beginning with the year following the expiry of the term for filing the corporate income tax return.