Montenegro has published legislation ratifying the OECD/G20 BEPS Multilateral Instrument, with a provisional list indicating that 40 of its tax treaties will be covered once the ratification instrument is deposited.
Montenegro has taken a further step toward implementing the OECD/G20 Base Erosion and Profit Shifting (BEPS) Multilateral Instrument (MLI), with its provisional list of reservations and notifications indicating that 40 of its tax treaties will be covered by the convention.
The law ratifying the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting was published in the Official Gazette on 31 December 2025. To bring the MLI into force for its covered agreements, Montenegro must now deposit its instrument of ratification.
The BEPS Convention, negotiated by more than 100 countries and jurisdictions under a mandate from the G20 Finance Ministers and Central Bank Governors, is a central outcome of the OECD/G20 BEPS Project. It is designed to update bilateral tax treaties and reduce opportunities for tax avoidance by multinational enterprises. Its measures address treaty abuse, the avoidance of permanent establishment status, and hybrid mismatch arrangements.
The convention also strengthens dispute resolution mechanisms, notably through an optional provision on mandatory binding arbitration, which has been adopted by 34 jurisdictions.
Under the convention, the MLI generally enters into force for a specific covered tax treaty on the first day of the month following a three-month period after both treaty partners have deposited their ratification instruments. Once in force, the MLI provisions generally apply from 1 January of the following year for withholding taxes, and for other taxes with respect to taxable periods beginning on or after the expiry of a six-month period following the date of entry into force.
Earlier, The OECD announced that Montenegro had signed the BEPS MLI on 12 November 2025.
