Romania has completed its internal procedures for the BEPS MLI to take effect for its tax treaty with Montenegro, with the treaty changes applying to specified taxes from 2027 and 2028.
Romania deposited an updated notification on 15 September 2026 confirming the completion of its internal procedures for the MLI to enter into effect for its tax treaty with Montenegro (formerly Yugoslavia), according to an OECD update.
Romania’s notification was required under its MLI reservation before the instrument could take effect for the Romania-Montenegro tax treaty.
The MLI provisions will apply to Romanian withholding taxes on amounts paid or credited to non-residents from 1 January 2027, to other Romanian taxes for taxable periods beginning on or after 1 January 2028, and to other Montenegrin taxes for taxable periods beginning on or after 15 April 2027.
The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (“Multilateral Instrument” or “BEPS MLI”) allows governments to modify existing bilateral tax treaties in a synchronised and efficient manner to implement the tax treaty measures developed during the BEPS Project, without the need to expend resources renegotiating each treaty bilaterally.
Earlier, Montenegro enacted the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 1 September 2026.
