New Rulebook Published on the Additional Corporate Income Tax
In the Official Gazette of the Republic of North Macedonia No. 270/25 dated 31 December 2025, a new Rulebook was published regulating the method of calculation, reporting, and payment of the additional corporate income tax, in accordance with the Law on the Global Minimum Corporate Income Tax.
What does the Rulebook regulate?
The Rulebook prescribes the method for calculating and paying the Qualified Domestic Minimum Top-up Tax (QDMTT), the form and procedure for submitting the Information Return on the Additional Tax and for reporting the designated Constituent Entity to the Public Revenue Office, the form and procedure for submitting the Additional Tax Return, as well as the form and manner of payment of the domestic top-up tax.
The calculation of the additional minimum tax is carried out in accordance with the OECD Global Anti-Base Erosion (GloBE) Model Rules, pursuant to Article 5.5 of the Law.
Who does the Law apply to?
The Law applies to multinational enterprise groups and large domestic groups that have generated consolidated revenues exceeding EUR 750 million in at least two of the last four fiscal years.
Which entities are exempt?
Entities with revenues below the EUR 750 million threshold are exempt from the obligation to pay the additional tax, as well as excluded entities defined by the Law (public institutions, international and non-profit organisations, pension and investment funds), and entities that meet the de minimis exclusion.
The de minimis exclusion applies where, at the jurisdictional level, the average qualified revenue is below EUR 10 million and the average qualified profit or loss is below EUR 1 million.
Key rules
A minimum effective taxation of 15% is ensured through the Qualified Domestic Minimum Top-up Tax (QDMTT), the Income Inclusion Rule (IIR), and the Undertaxed Payments Rule (UTPR).
Expert commentary
The Qualified Domestic Minimum Top-up Tax applies to multinational enterprises and large domestic groups, regardless of whether the ultimate parent entity is foreign or domestic. Its introduction ensures that the top-up tax on low-taxed profits generated in North Macedonia is collected locally.
In practice, affected groups should timely assess their effective tax rate and their obligations for the calculation, reporting, and payment of the additional tax in accordance with the new Rulebook.
PKF Nova Konsalting
06 January 2026