Tax Alert: Planned amendments to the rules for transfer pricing documentation

March 14th, 2023

There are proposed amendments to the Corporate Income Tax Law currently in Parliamentary procedure according to which, the obligation to submit the Transfer Pricing Report to the Public Revenue Office until 30 September of the following year, for the previous year, is abolished. 

Nonetheless, taxpayers who meet the statutory requirements will continue to have the obligation to prepare the Report in the prescribed form, as well as to keep the report for 10 years as of the end of the year to which it refers.

The Public Revenue Office may request the Transfer Pricing Report after 30 days from the deadline for submitting the CIT return, and the taxpayers will have to submit the Report within 15 days as of the request. Based on this amendment, the deadline for the preparation of transfer pricing documentation effectively will be shortened until May 1 of the following year, for the previous year.

Taxpayers who have an obligation to prepare and keep a Transfer Pricing Report should report data on related parties’ transactions on a newly prescribed Form P/TC. This form would be submitted to the PRO together with the CIT Return.

This provision is expected to be applicable as of 1 January 2023. As an exception, the obligation to submit a Transfer Pricing Report for FY2022 until 30 September 2023, stands.

How can we help you?

PwC North Macedonia can help you with:

1. Assistance and advice in relation to the application of transfer pricing rules.
2. Preparation of documentation for transfer prices in a prescribed form.
3. Development of a group policy for transfer prices.
4. Specialized training courses for employees on transfer pricing.

For more details please refer to your usual contact within PwC or the persons indicated below:

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Miroslav Marchev
Partner, Tax and Legal Services
Mobile: +389 70 270 177
E-mail: miroslav.marchev@pwc.com

Eli Bocevska Grueska
Senior Tax Manager
Mob: + 389 72 307 510
E-mail: eli.bocevska.grueska@pwc.com

Ana Shajnoska Georgijevska
Senior Tax Manager
Mobile: + 389 72 307 509
E-mail: ana.shajnoska@pwc.com