Montenegro

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. It is expected that the BEPS Convention will enter into force once the necessary formal steps are completed and the relevant instruments are duly deposited.

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 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.