Montenegro’s Ministry of Finance issued a Rulebook setting out the reporting requirements, definitions and dissemination procedures for the Pillar Two GloBE Information Return (GIR). The Rulebook took effect on 9 October 2026.
Montenegro has published a Rulebook in the Official Gazette establishing requirements for submitting the Pillar Two GloBE Information Return (GIR).
The Rulebook entered into force on 9 October 2026.
Reporting requirements
The Ministry of Finance adopted the Rulebook on the Detailed Manner of Top-up Tax Reporting and the Form and Content of the Top-up Tax Information Return under Article 14k, paragraph 6 of the Law on Tax Administration and Article 28, paragraph 9 of the Law on Global Minimum Corporate Income Tax (Official Gazette of Montenegro, No. 33/26).
Article 1 establishes that the Rulebook prescribes the detailed procedures for reporting top-up tax and the form and content of the top-up tax information return, referred to as the Return.
Key definitions
Article 2 defines key terms used in the reporting framework, including implementing member state or jurisdiction, qualified income inclusion rule, qualified undertaxed profits rule and dissemination approach.
An implementing member state or jurisdiction has implemented a qualified income inclusion rule (IIR), a qualified undertaxed profits rule (UTPR), or both, during the relevant reporting fiscal year.
A qualified income inclusion rule enables the parent entity of a multinational enterprise group or a large domestic group to calculate and pay its allocable share of top-up tax relating to low-taxed constituent entities. The rule must be equivalent to the global rules, applied consistently with them and must not provide benefits connected with its implementation.
A qualified undertaxed profits rule allows a jurisdiction to collect its allocable share of a multinational enterprise group’s top-up tax that has not been collected under the income inclusion rule for low-taxed constituent entities. It must also meet the requirements for equivalence, consistent application and the absence of related benefits.
Dissemination of the return
The Rulebook outlines a dissemination approach under which relevant parts of the Return are forwarded to the competent authorities of member states or jurisdictions in accordance with the global rules.
The general section of the Return must be submitted to implementing jurisdictions where the ultimate parent entity or constituent entities of the multinational enterprise group are located.
For jurisdictions applying only a qualified domestic top-up tax (QDMTT), the general section must be submitted without the summary of information from Section 1.4 of the Return. This applies in specified cases involving constituent entities, joint ventures, joint venture group members, stateless constituent entities and stateless joint ventures.
The Rulebook also provides for relevant parts of the Return to be submitted to jurisdictions that have taxing rights under the global rules or apply the specified qualified rules.
Earlier, Montenegro’s parliament adopted the Law on Global Minimum Corporate Income Tax, aligning the country’s tax framework with international standards under the OECD Pillar Two initiative.
