Montenegro

Implementation of BEPS Convention

Montenegro signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS Convention) on 12 November 2025 and subsequently ratified it on 27 December 2025. Montenegro deposited its instrument of ratification for the BEPS Convention, and it will enter into force for Montenegro on September 1, 2026.

Accession of Montenegro to EU

Montenegro is currently in the process of accession to the EU and, as part of this process, is aligning its domestic tax legislation with EU requirements.

Certain legislative changes have already been adopted and are expected to become effective upon Montenegro's accession to the EU.

Global Minimum Corporate Income Tax

In early 2026, Montenegro adopted the Law on the Global Minimum Corporate Income Tax, introducing a top‑up tax to ensure a minimum level of taxation for the profits of multinational enterprise (MNE) groups and large domestic groups operating in Montenegro. In the coming period, the Ministry of Finance is expected to prescribe the filing procedure, forms, and required data and documentation related to the top-up tax.

For more detailed information and the most recent updates, please visit PwC’s Pillar Two Country Tracker.