The owner of a small hotel wrote to the Public Revenue Office (UJP). Every month the hotel receives two invoices from abroad: a commission from Booking for the nights sold, and a bill from Facebook for its ads. Both are paid by card. The question was simple — does the hotel have to withhold tax on them?
UJP's answer (opinion of 5 June 2025) split the two invoices. Booking — no. Facebook — yes.
What withholding tax is
When a Macedonian company pays certain types of income to a foreign company, it must withhold tax at the time of payment and pay it over together with the payment (Article 20 of the Law on Profit Tax). The rate is 10% of the gross income (Article 22).
Not every payment abroad is caught. Article 21 lists the income types: dividends, interest, royalties, rent for property in the country and — in point 7 — management, consulting, financial services and research and development services.
At first sight, ads are none of these. The Rulebook, however, puts them right there: research and development services include "advertising, market research, advertising in the media, trade fairs" (Article 11 of the Rulebook). A Facebook ad is advertising in a medium. So it is subject to withholding tax.
Booking's commission is intermediation — it is not on the list, so there is no withholding tax.
Where the zero comes from
Meta, which issues the ad invoices, is an Irish company. North Macedonia and Ireland have a double taxation convention, and according to UJP, under that convention this income is taxed in Ireland — the Macedonian withholding tax rate is 0%.
The law allows the treaty rate to be lower than 10% (Article 23(1)). It ties this to one condition, though: the payer must hold a certified form or an approval from UJP (Article 23(2)).
The rule: the treaty's 0% does not apply by itself. If you do not have a certified form or a UJP approval when you pay, you must withhold and pay 10% of the gross amount — even though the treaty says 0%.
How to get to 0%
The Rulebook provides two forms (Article 12):
- ZD-O/DP — a request for exemption from tax on other income, certified by the Irish tax authority; or
- ZD-DO — a request for tax exemption, with a certificate of residence of the recipient issued by the Irish tax authority, and a translation by a certified court translator.
The form is filed before each payment. For ads, which are paid repeatedly on the same basis, it is enough to file it before the first payment (Article 12 of the Rulebook). UJP issues the approval within 30 days (Article 23(5) of the Law).
The certificate of residence must cover the period in which you pay — a new year needs a new certificate.
In practice, UJP is given:
- Meta's certificate of residence from the Irish tax authority, with a translation — a new one each year;
- the ZD-DO form;
- a printed copy of Meta's Terms of Service, since you have no other contract with it;
- the invoice or a statement of payments;
- a written request for the exemption to cover the whole year, because the payments are frequent.
What if you are already paying without a form
Then, under the law, the tax should have been withheld on every payment. Meta will not charge you 10% less — your card is debited for the full amount — so the company pays the tax out of its own pocket.
| Example: one year of ads | Amount |
|---|---|
| Invoices from Meta | MKD 300,000 |
| Withholding tax without a form (10%) | MKD 30,000 |
| Withholding tax with a certified form (0%) | MKD 0 |
At year end there is one more obligation: a report on the withholding tax paid, filed with UJP by 15 February of the following year (Article 24).
What to check in your company
Take this year's invoices from abroad and split them into two groups. Booking, Airbnb and similar intermediation — no withholding tax there. Ads (Facebook, Instagram, Google), market research, consulting, licences and software with copyright — here the question is open, and the answer depends on the treaty with the supplier's country and on whether the form arrived in time.
Google and LinkedIn also invoice their ads through Irish companies, so the procedure is the same as with Meta. If the invoice comes from a US company, there is no double taxation convention, so the 10% stays.
VAT is a separate story: for services from a foreign supplier, the recipient calculates the VAT. We explained that in The Microsoft invoice has no VAT.