This makes Montenegro the 107th jurisdiction to join the landmark agreement to strengthen tax treaties, which now covers over 2,000 bilateral tax treaties.
The OECD announced that Montenegro has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI), also known as the “BEPS Convention” on 12 November 2025.
Montenegro’s provisional list of reservations and notifications under the BEPS MLI indicates that 40 of its tax treaties will be covered by the convention.
With this signature, Montenegro becomes the 107th jurisdiction to join the agreement to strengthen tax treaties, which now covers over 2,000 bilateral tax treaties.
Presently, 90 jurisdictions have either ratified, accepted, or approved the BEPS Convention, resulting in the modification of over 1,600 treaties. Around 400 additional treaties will be modified once the BEPS Convention will have been ratified by all Signatories.
The BEPS Convention, negotiated by more than 100 countries and jurisdictions under a mandate from the G20 Finance Ministers and Central Bank Governors, is one of the most prominent results of the OECD/G20 BEPS Project. It is the world’s leading instrument for updating bilateral tax treaties and reducing opportunities for tax avoidance by multinational enterprises. Measures included in the BEPS Convention address treaty abuse, strategies to avoid the creation of a “permanent establishment”, and hybrid mismatch arrangements.
The BEPS Convention also enhances the dispute resolution mechanism, especially through the addition of an optional provision on mandatory binding arbitration, which has been taken up by 34 jurisdictions.
