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Tax Inspections by the Public Revenue Office in North Macedonia

KEY TAKEAWAYS

  • The Public Revenue Office (PRO) conducts two types of inspections: external controls and tax audits.
  • External controls are increasing: 3,113 in 2024 → 4,003 in 2025 → 669 in Q1 2026 alone.
  • Irregularity rates are rising sharply: 37.6% in 2024 → 48.1% in 2025 → 52% in Q1 2026.
  • VAT inspections are the most frequent category — 1,635 in 2025, of which 639 were irregular.
  • Fiscalisation audit irregularity rate reached 88% in 2025 and 83% in Q1 2026 — the highest risk category.
  • Skopje has the highest number of inspected entities but Tetovo showed the highest irregularity rates in several categories.
  • Companies should maintain complete tax records, VAT documentation and fiscalisation equipment at all times.

 

Tax inspections by the Public Revenue Office (PRO) are a routine and increasingly active feature of the business environment in North Macedonia. The number and intensity of inspections have been rising year on year, and the irregularity rate — the share of inspections that identify problems — is increasing in parallel. For any company operating in North Macedonia, understanding how the inspection system works and maintaining adequate compliance is essential. This page is part of our practice in business and corporate law. For related compliance questions, see our guide on 7 compliance risks for managers in North Macedonia.

What Is a Tax Inspection?

The Public Revenue Office conducts tax inspections to verify that legal and natural persons are meeting their tax obligations. There are two main categories:

  • External controls — field-based inspections of business premises and operations, covering VAT, personal income tax, corporate income tax, games of chance, technical/spatial requirements and other categories.
  • Tax audits — in-depth audits of specific tax obligations, primarily focused on fiscalisation compliance. These audits have a significantly higher irregularity detection rate than external controls.

Both types can result in additional tax assessments, penalties and, in serious cases, criminal referrals. The PRO also publishes annual inspection statistics on its website, which provide a useful picture of enforcement activity by region and tax category.

What Triggers a Tax Inspection?

Inspections in North Macedonia can be triggered by:

  • Risk-based selection — the PRO uses risk profiling to identify taxpayers with patterns that suggest under-reporting, discrepancies between VAT filings and income declarations, or anomalies compared to sector averages;
  • Routine sector sweeps — the PRO periodically conducts targeted inspections in specific sectors (retail, hospitality, construction, gaming) regardless of individual risk indicators;
  • Complaints and third-party information — information received from customers, suppliers or other authorities can trigger an inspection;
  • Follow-up inspections — companies that have previously had irregularities identified are subject to follow-up controls to check whether the problem has been corrected;
  • Fiscalisation spot checks — the PRO regularly verifies that fiscalisation equipment is operational, properly configured and used for every transaction as required by law.

Inspection Statistics — 2024 and 2025

The following data is sourced from the Public Revenue Office statistics published at ujp.gov.mk.

External Controls 2024 (01.01.–31.12.2024)

Category

Total controls 2024

Irregular

Irregularity rate

VAT

1,225

486

39.7%

Personal income tax 

294

244

83.0%

Corporate income tax

255

123

48.2%

Games of chance

32

5

15.6%

Technical/spatial (gaming)

399

40

10.0%

Other controls

908

274

30.2%

TOTAL

3,113

1,172

37.6%

 

Tax Audits 2024 (01.01.–31.12.2024)

Category

Total audits 2024

Irregular

Irregularity rate

Fiscalisation audits

696

231

33.2%

Other tax audits

17

13

76.5%

TOTAL

713

244

34.2%

 

External Controls 2025 (01.01.–31.12.2025)

Category

Total controls 2025

Irregular

Irregularity rate

VAT

1,635

639

39.1%

Personal income tax 

453

351

77.5%

Corporate income tax 

323

181

56.0%

Games of chance

129

42

32.6%

Technical/spatial 

317

21

6.6%

Other controls

1,146

693

60.5%

TOTAL

4,003

1,927

48.1%

 

Tax Audits 2025 (01.01.–31.12.2025)

Category

Total audits 2025

Irregular

Irregularity rate

Fiscalisation audits

1,161

1,059

91.2%

Other tax audits

71

26

36.6%

TOTAL

1,232

1,085

88.1%

 

Controls Q1 2026 (01.01.–31.03.2026)

Category

Total controls Q1 2026

Irregular

Irregularity rate

VAT

258

115

44.6%

Personal income tax 

91

76

83.5%

Corporate income tax

37

26

70.3%

Games of chance

14

3

21.4%

Technical/spatial (gaming)

51

4

7.8%

Other controls

218

124

56.9%

TOTAL — External controls

669

348

52.0%

TOTAL — Tax audits

129

104

80.6%

 

What the Statistics Tell Us

Several trends stand out from the 2024–2026 data:

  • The total volume of inspections is growing sharply — from 3,113 external controls in 2024 to 4,003 in 2025, with Q1 2026 already at 669 (suggesting a 2025+ pace for the full year);
  • The irregularity rate is increasing — 37.6% in 2024, 48.1% in 2025, 52% in Q1 2026. This reflects both more intensive targeting and genuine compliance gaps;
  • Personal income tax inspections have an exceptionally high irregularity rate — 83% in 2024, 77.5% in 2025, 83.5% in Q1 2026 — making this the highest-risk category for businesses;
  • Fiscalisation audits are the single highest-risk category — over 91% irregularity rate in 2025, and 80%+ in Q1 2026. Any business required to use a fiscal device should treat compliance as a priority;
  • Skopje accounts for the largest share of inspections in absolute terms, but Tetovo and Bitola show disproportionately high irregularity rates in several categories.

What Happens During a Tax Inspection?

External controls are typically conducted without prior notice. An inspector arrives at the business premises, identifies themselves and requests access to the relevant documentation. The inspection may cover:

  • VAT records and filings — checking that input and output VAT is correctly reported and that VAT invoices are in order;
  • Fiscalisation compliance — verifying that a fiscal device is operational, that every transaction is being fiscalised and that the fiscal memory is intact;
  • Employment records — checking that employees are properly registered and that salaries are paid and declared correctly;
  • Corporate income tax — reviewing the consistency between the company’s financial statements and its tax filings;
  • Specific documentation depending on the category of inspection (e.g. gaming licences, price labelling, contracts).

After the inspection, the inspector prepares a report. If irregularities are found, the company is typically given an opportunity to respond or correct the issue, after which a formal decision is issued imposing additional tax, interest and/or penalties.

 

Practical Checklist

To reduce the risk of irregularities in a tax inspection, verify the following regularly: (1) VAT documentation — ensure all VAT invoices are correctly issued, input VAT is supported by valid invoices, and VAT returns are filed on time and accurately. (2) Fiscalisation — verify that your fiscal device is operational and properly configured. Fiscalise every transaction — the 91%+ irregularity rate in fiscalisation audits shows this is the PRO’s most productive enforcement area. (3) Employee registration — all employees must be registered with the Employment Agency before starting work. Unregistered workers are one of the most common findings in inspections. (4) Salary reporting — personal income tax is declared and paid on time. The 77–83% irregularity rate in PDD inspections reflects widespread under declaration. (5) Record retention — keep all tax-relevant documentation (contracts, invoices, payroll records, VAT filings) for the statutory retention periods. Inability to produce documents during an inspection is itself a finding. (6) Post-inspection follow-up — if you have had a previous inspection with findings, correct the identified issues immediately. Follow-up inspections are standard practice and repeated violations result in higher penalties. For legal assistance during or after a tax inspection, contact our business law team.

 

Frequently Asked Questions

Does the PRO notify companies before a tax inspection?

External controls (field inspections) are typically conducted without prior notice. Tax audits may involve advance notification, depending on the scope and nature of the audit. In practice, most routine fiscalisation and VAT spot checks arrive unannounced.

What happens if irregularities are found?

If the inspection identifies irregularities, the PRO issues a formal decision assessing additional tax, interest for late payment, and administrative penalties. The company has the right to respond to the inspection report before the final decision is issued. Decisions can be appealed through the administrative and court system.

Which category of business is most frequently inspected?

Skopje has the highest absolute number of inspections, reflecting the concentration of registered businesses in the capital. In terms of irregularity rates, fiscalisation and personal income tax inspections have the highest rates of findings — these are the categories where the PRO is most likely to identify problems.

Can a company challenge an inspection finding?

Yes. Companies have the right to submit observations on the inspection report before the final decision is issued, and to appeal the final decision. An appeal can be filed with the State Appeals Commission and subsequently challenged before the Administrative Court. Legal representation is strongly recommended for any substantive dispute with the PRO.

Where can I find the PRO’s official inspection statistics?

The Public Revenue Office publishes annual and quarterly inspection statistics on its website. The statistics are available in Macedonian at ujp.gov.mk/mk/statistika.

 

ABOUT THE AUTHOR

Vedran Lalicic

Attorney at Law | Lalicic & Partners, Skopje, North Macedonia

Practice areas: Business and corporate law, Real estate, Litigation

 

Last updated: August 2026

Note: The above does not constitute legal advice and in no way can be accepted or understood as an instruction to act in a specific case. Each legal situation has its own characteristics that should be reviewed at separately, and for that reason we recommend that you contact a professional – a lawyer – for legal advice.