The Rulebook on the Manner of Calculation and Collection of the Top-up Tax, adopted pursuant to the Law on the Global Minimum Corporate Income Tax, was published in the Official Gazette of the Republic of North Macedonia No. 270 dated 31 December 2025.

The Rulebook further regulates the practical aspects of the application of the global minimum tax rules (Pillar Two), aligned with the OECD models and rules, and their implementation within the national tax system.

Key Aspects of the Rulebook

The Rulebook regulates:

  • the manner of calculation and collection of the Qualified Domestic Minimum Top-up Tax;
  • the form, content and manner of submission of the relevant tax returns:
    • Top-up Tax Information Return,
    • Top-up Tax Return (Form “DDD/P”),
    • Qualified Domestic Minimum Top-up Tax Return (Form “KDDD/P”);
  • mandatory electronic filing, including cases where the amount of calculated tax is “0”.

For groups with multiple constituent entities in the Republic of North Macedonia, the Rulebook provides for the designation of one responsible entity to submit a consolidated return on behalf of the group.

Calculation and Technical Rules

Pursuant to the Rulebook:

  • the effective tax rate and top-up tax percentages are rounded to four decimal places;
  • amounts denominated in foreign currencies are converted into denars using the middle exchange rate of the National Bank of the Republic of North Macedonia applicable for the last month of the fiscal year.

Deadlines

The Top-up Tax Information Return must be submitted within 15 months following the end of the fiscal year.

For 2024, the filing deadline is 30 June 2026.

The domestic top-up tax must be paid within 30 days following the expiry of the filing deadline, i.e. no later than 30 July 2026 for the 2024 fiscal year.

Entry into Force

The Rulebook enters into force on the day following its publication in the Official Gazette.

The Rulebook provides a comprehensive regulatory framework for the practical implementation of the global minimum corporate income tax. Companies that may fall within its scope should assess their obligations in a timely manner and prepare for compliance with the new rules.

 

Contact us for further clarification regarding the application of the Rulebook and the Law on the Global Minimum Corporate Income Tax.