A parliamentary committee in Montenegro has approved changes to the Global Minimum Corporate Tax Law, further aligning domestic rules with Council Directive (EU) 2022/2523 and shortening the filing deadline for top-up tax returns.
Montenegro’s Committee on Economy, Finance and Budget of the Parliament approved a proposal on 5 November 2026 for the Bill on Amendments and Supplements to the Global Minimum Corporate Tax Law, recommending that Parliament adopt it. The committee issued its report on 6 November 2026, following its 159th session.
The vote was unanimous, with seven members in favour. The bill, registered as EPA 1202 XXVIII, was sponsored by MPs Seid Hadžić and Milan Zečević.
EU alignment
Hadžić told the committee the amendments would bring Montenegro’s tax legislation closer to EU law, specifically Council Directive (EU) 2022/2523 on ensuring a global minimum level of taxation for multinational enterprise (MNE) groups and large domestic groups. The changes focus on refining rules for the Qualified Domestic Minimum Top-up Tax (QDMTT) and revising tax return filing timelines.
Technical changes
The amendments clarify terminology and rules for determining the tax base, computing the top-up tax and allocating it among constituent entities. Key terms, including qualified profit or loss, qualified revenue and qualified domestic top-up tax, have been updated.
The draft also refines the rules for identifying entity locations. It sets out detailed formulas for calculating the effective tax rate (ETR) and the top-up tax.
Revised filing deadlines
Under the proposal, the deadline for submitting the Top-up Tax Information Return and the Qualified Domestic Minimum Top-up Tax return would be cut from 18 months to 15 months after the end of the fiscal year.
For the first year of application, however, the 18-month deadline would be kept. This is meant to give taxpayers enough time to adjust their systems, gather data and meet their compliance obligations.
Next steps
The Government of Montenegro issued an opinion on 2 October 2026 supporting the draft law. The bill’s sponsors have announced further amendments. MP Slađana Kaluđerović has been appointed the committee’s rapporteur for the parliamentary session, where the bill will now be considered.
