Transfer Pricing — Related party rules in MK
Transfer prices are prices at which transactions occur between related parties (parent-subsidiary companies, companies with a common owner). Tax authorities require these prices to be at 'arm's length' — the same as in an open market.
Definition
Transfer prices are prices at which transactions occur between related parties (parent-subsidiary companies, companies with a common owner). Tax authorities require these prices to be at 'arm's length' — the same as in an open market.
Details
In MK, transfer pricing documentation is required for: companies with turnover above 50M MKD and related-party transactions above 5M MKD annually. Methods: comparable uncontrolled price (CUP), cost-plus, resale price. Penalties for non-compliance: tax base adjustment + fine.
Example
DOOEL 'A' in Skopje sells software to related company 'B' in Germany for 50 EUR/hr. It charges unrelated clients 80 EUR/hr. UJP may adjust the base to 80 EUR/hr.