Montenegro’s Parliament has approved the Global Minimum Corporate Tax Law, introducing a 15% minimum rate for large multinational groups and a domestic top-up tax, with compliance required within 18 months.
The Parliament of Montenegro approved the Global Minimum Corporate Tax Law on 27 February 2026, introducing a 15% minimum effective tax rate for large multinational groups operating in the jurisdiction.
The legislation aligns Montenegro’s tax framework with the global minimum taxation standards developed under Organisation for Economic Co-operation and Development (OECD) Pillar Two initiative and includes a Qualified Domestic Minimum Top-up Tax to protect domestic tax revenues.
15% minimum tax rate: Applies to constituent entities of groups reporting at least EUR 750 million in annual consolidated revenue in two of the last four fiscal years.
Qualified Domestic Minimum Top-up Tax (QDMTT): Introduces a domestic top-up tax to safeguard Montenegro’s revenue from low-taxed domestic profits.
Exclusions: The law does not implement the Income Inclusion Rule (IIR) or the Undertaxed Profits Rule (UTPR) at this stage.
Compliance deadlines: Affected entities must electronically file their tax returns within 18 months after the end of the fiscal year.
The law is expected to strengthen Montenegro’s corporate tax framework and ensure compliance with the OECD’s Pillar Two standards on global minimum taxation. It will take effect once it has been signed and published in the Official Gazette, and it will apply starting from 1 January 2026.
