The treaty’s provisions will take effect from 1 January 2026.
The income and capital tax treaty between Luxembourg and Montenegro entered into force on 1 October 2025.
Under the agreement, dividends are taxed at 5% if the recipient company holds at least 10% of the distributing company’s capital, and 10% in all other cases. Interest payments are generally subject to a 10% withholding tax.
Royalties on copyrights of literary, artistic, or scientific works—including films and recordings for radio, television, or other reproduction—are taxed at 5%. Royalties for patents, trademarks, designs, models, plans, trade secrets, processes, computer software, or technical and commercial information carry a 10% withholding rate.
The treaty’s provisions will take effect from 1 January 2026.
Earlier, Luxembourg ratified both the Luxembourg-Montenegro Income and Capital Tax Treaty (2024) on 18 December 2024.
