DT12563 | Double Taxation Relief Manual: Macedonia: interest

Interest arising in Macedonia and paid to a resident of the United Kingdom who is the beneficial owner of the interest is taxable in Macedonia at a rate not exceeding 10 per cent (Article 11(2)).

Interest arising in Macedonia and paid to a United Kingdom resident is, however, exempt from Macedonian tax if:

• the interest is paid in respect of a loan granted or a credit extended by an enterprise to another enterprise (Article 11(3)(a)); or

• the interest is paid to the Government of the United Kingdom, or to its political subdivisions or local authorities or to public entities of the United Kingdom (Article 11(3)(b)); or

Where, however, the interest is effectively connected with a permanent establishment which the United Kingdom resident recipient has in Macedonia, the provisions of the Business Profits Article (Article 7) will apply.