Montenegro has signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI) on 12 November 2025.
Montenegro’s parliament adopted the draft law ratifying the Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 27 December 2025.
Once the internal ratification process is complete, Montenegro will deposit its instrument of ratification, bringing the MLI into force for the covered tax treaties.
Earlier, Montenegro’s government adopted a series of draft laws, amendments, and international agreements on 11 December 2025, which included a draft law for the ratification of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI).
With this signature, Montenegro became the 107th jurisdiction to join the agreement to strengthen tax treaties, which now covers over 2,000 bilateral tax treaties.
Currently, 90 jurisdictions have either ratified, accepted, or approved the BEPS Convention, resulting in the modification of more than 1,600 treaties. Approximately 400 additional treaties will be modified once all Signatories ratify the BEPS Convention.
Montenegro 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.
