(1) Dividends paid by a company which is a resident of the
sovereign territory of a Contracting Party to a resident of the
sovereign territory of the other Contracting Party may be taxed
in the sovereign territory of that other Contracting Party.
(2) However, such dividends may also be taxed in the
sovereign territory of the Contracting Party of which the
company paying the dividends is a resident and according to
the laws of the state of that Contracting Party, but if the
beneficial owner of the dividends is a resident of the sovereign
territory of the other Contracting Party, the tax so charged shall
not exceed
a) 5 per cent of the gross amount of the dividends if the
beneficial owner is a company (other than a partnership)
which holds directly at least 10 per cent of the capital of the
company paying the dividends;
b) 15 per cent of the gross amount of the dividends in all other
cases.
This paragraph shall not affect the taxation of the company in
respect of the profits out of which the dividends are paid.
(3) The term “dividends” as used in this Article means
income from shares, “jouissance” shares or “jouissance” rights,
mining shares, founders' shares or other income which is
subjected to the same taxation treatment as income from
shares by the laws of the State of which the company making
the distribution is a resident and distributions on certificates of
an investment fund or investment trust.
(4) The provisions of paragraphs 1 and 2 shall not apply if the
beneficial owner of the dividends, being a resident of the
sovereign territory of a Contracting Party, carries on business in
the sovereign territory of the other Contracting Party of which
the company paying the dividends is a resident, through a
permanent establishment situated therein, or performs in that
other sovereign territory independent personal services from a
fixed base situated therein, and the holding in respect of which
the dividends are paid is effectively connected with such
permanent establishment or fixed base. In such case the
provisions of Article 7 or Article 14, as the case may be, shall
apply.
(5) Where a company which is a resident of the sovereign
territory of a Contracting Party derives profits or income from
the sovereign territory of the other Contracting Party, that other
Contracting Party may not impose any tax on the dividends
paid by the company, except insofar as such dividends are paid
to a resident of the sovereign territory of that other Contracting
Party or insofar as the holding in respect of which the dividends
are paid is effectively connected with a permanent establishment
or a fixed base situated in the sovereign territory of that other
Contracting Party, nor subject the company's undistributed
profits to a tax on the company's undistributed profits, even if
the dividends paid or the undistributed profits consist wholly or
partly of profits or income arising in the sovereign territory of
such other Contracting Party.
de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Macedonian as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-north-macedonia-2010-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2006-07-13; consent law 2010-10-16; gazette publication 2010-10-22. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 29.11.2010, 16.01.2018. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Later amending protocol signed 2016-11-14, entered into force 2018-01-16, general application 2019-01-01; NOT included in this base source. Tax-specific application needs review. Source implementing law expressly publishes the treaty in the corrected version resulting from the exchange of notes dated 2008-07-23. Those corrections are incorporated by the official publication, not by this reader. The separately headed exchange-of-notes document is not printed in this retained PDF; do not mistake the law reference for a complete separate notes reader. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2016-11-14; entry into force: 2018-01-16; general application from: 2019-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription
BGBl. 2010 II S. 1153 | de-north-macedonia-2010-base | de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22 | Article 10 | en | Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed. | /library/treaties/de-north-macedonia-2010-base/en/articles/article-10/
Source, edition and limits
Source edition
de-north-macedonia-2010-base | BGBl. 2010 II S. 1153 | signed 2006-07-13 | published 2010-10-22 | Signed: 2006-07-13 | Gazette publication: 2010-10-22
Source form
official-publication PDF with native text layer; reader is a machine transcription
Source scope
original implementing law, bilingual base treaty and accompanying protocol; not a current consolidated text
Retrieved
2026-09-30
Text and language scope
This source supplies German and English versions. The signing clause also identifies Macedonian as authentic; that third version is NOT present in this reader. Missing here does not mean globally unavailable. Unreviewed coordinate-based machine transcription of this original source edition only. Printed line breaks, hyphens and uncertain token spacing are retained, not silently corrected. Treaty preamble, closing formula, protocol and shared signatures are separate retained assets, not part of the last article. Full supplements: /review/de-north-macedonia-2010-base/. PDF page links identify pages, not verified paragraph correspondence.
Review status
Pending human wording, completeness, source-authority, currentness, alignment and rendering review. No legal review performed.
Currentness
Original source edition; not a verified current-law consolidation. Unknown as current law. Signed 2006-07-13; consent law 2010-10-16; gazette publication 2010-10-22. Edition ID year is not a signature date. Treaty entry into force: not resolved as a single source-bound field by the retained audit. Roster general application: 2011-01-01 (not a universal tax-specific rule). Cached official article entry statements (may refer to multiple instruments): 29.11.2010, 16.01.2018. Evidence is the retained 2026-10-01 agent audit of source PDF, 2026-01-01 roster and cached official HTML, not a fresh current-law determination. Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force.
Protocols and later instruments
Printed signature protocol retained separately and not merged into articles. Later amending protocol signed 2016-11-14, entered into force 2018-01-16, general application 2019-01-01; NOT included in this base source. Tax-specific application needs review. Source implementing law expressly publishes the treaty in the corrected version resulting from the exchange of notes dated 2008-07-23. Those corrections are incorporated by the official publication, not by this reader. The separately headed exchange-of-notes document is not printed in this retained PDF; do not mistake the law reference for a complete separate notes reader. MLI application and complete later amendments, replacements or suspensions are NOT verified. No developments after the retained roster snapshot are certified. This is NOT a current consolidated instrument. Source-triage warnings: Bounded agent triage, no qualified wording/alignment/legal review. No exhaustive verification of all later 2026 developments. Matching digest proves retained source identity, not legal force. Known related/later instruments NOT included in this source (agent triage, not exhaustive): amending-protocol; signature date: 2016-11-14; entry into force: 2018-01-16; general application from: 2019-01-01; limit: Exact tax-specific application remains for protocol review.
Text language and status
en · authentic-language-transcription · machine-transcription