The protocol amending the income tax treaty between Switzerland and North Macedonia has entered into force, with its changes to apply from 1 January 2027.
The protocol amending the income tax treaty between Switzerland and North Macedonia entered into force on 22 October 2026, according to information published on 5 November 2026. Its provisions will apply from 1 January 2027.
The protocol, dated 19 May 2021, amends the agreement between the Swiss Confederation and the Republic of North Macedonia for the avoidance of double taxation with respect to taxes on income and on capital. It entered into force after both countries completed their ratification procedures.
The protocol implements the minimum standards of the OECD for income tax treaties. It contains an abuse clause that refers to the main purpose of an arrangement or transaction, which ensures that the treaty is not abused.
It also contains an administrative assistance clause, in line with the international standard for the exchange of information upon request. In addition, the protocol introduces an arbitration clause, which will provide legal certainty.
With the protocol now in force, the amended income tax treaty will govern the taxation of income and capital between Switzerland and North Macedonia from 1 January 2027.
