The OECD confirmed that Montenegro deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 6 May 2026, with the Convention set to enter into force for the country on 1 September 2026.
The OECD announced that Montenegro deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) on 6 May 2026. The BEPS Convention will enter into force for Montenegro on 1 September 2026.
By depositing its instrument of ratification, Montenegro reaffirmed its commitment to tackling tax treaty abuse and preventing base erosion and profit shifting (BEPS) by multinational enterprises. The Convention is designed to ensure consistent implementation of treaty-related BEPS measures across jurisdictions.
As of now, 91 jurisdictions have ratified, accepted or approved the BEPS Convention, leading to the modification of more than 1,600 tax treaties. A further 400 treaties are expected to be amended once all Signatories complete their ratification processes.
Developed by over 100 countries and jurisdictions under the mandate of G20 Finance Ministers and Central Bank Governors, the BEPS Convention is a key outcome of the OECD/G20 BEPS Project. It serves as a global instrument to update bilateral tax treaties and reduce opportunities for tax avoidance by multinational enterprises.
Its provisions address treaty abuse, arrangements designed to avoid the creation of a “permanent establishment”, and hybrid mismatch structures. The Convention also strengthens tax treaty dispute resolution mechanisms, including an optional provision for mandatory binding arbitration, which has been adopted by 34 jurisdictions.
