Montenegro’s Government issued a bill to ratify its income tax treaty with Spain, setting withholding tax rates for dividends, interest and royalties. The treaty was set to take effect one month after the exchange of ratification instruments.
Montenegro’s Government has issued the bill for the ratification of the income tax treaty with Spain, following approval granted during a government session on 24 September 2026.
The treaty applies to Montenegrin personal income tax and corporate profit tax, as well as Spanish income tax on individuals, corporation tax, and income tax on non-residents.
Dividends are subject to 5% where the beneficial owner is a company holding at least 5% of the paying company’s capital, and 10% otherwise. Interest is generally subject to 10%, with exemptions for certain government-related payments and qualifying financial institutions or pension state funds. Royalties are subject to 5% for specified copyrights and 10% for patents, trademarks, designs, secret formulas and related industrial, commercial or scientific information.
The treaty will take effect one month after the exchange of the ratification instruments and will apply from 1 January of the year following its entry into force.
