Macedonia - Anti-abuse provisions

Macedonia

Anti-abuse provision: Main purpose test

Protocol V:

V-3. In case a company does not fulfill one of the conditions laid down in paragraph 2 above, the provisions of paragraph 1 above shall also not apply with respect to such company if it is established in mutual agreement by the competent authorities of the Contracting States, in conformity with Article 27 of the Convention, that such company is not established or maintained in the Macedonian Contracting State mainly for the purpose of ensuring the benefits of paragraph 3 of Article 10 of the Convention and provided that the company receiving the dividends is a Macedonian resident and the beneficial owner of the dividends.