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On 27 February 2023, the Ministry of Finance of Montenegro released the Draft Law on Solidarity Contribution (hereinafter: “Draft Law”) for public debate. The public debate is expected to last until 20 March 2023. During this time all interested parties will be able to submit comments and suggestions to the Draft Law.

The main features of the Draft Law are the following:

  • The solidarity contribution is introduced as an extraordinary and temporary measure that will apply only for 2023 and 2024;
  • The solidarity contribution applies to all corporate taxpayers with annual revenue in excess of EUR 5,000,000 in the year preceding the year of assessment (2022 and/or 2023). Solidarity contribution represents additional tax applicable in addition to corporate income tax payable for 2022 and 2023;
  • The tax base is assessed on the taxable profits, determined in accordance with the Corporate Income Tax (hereinafter: “CIT”) Law and realized in the fiscal years 2022 and 2023 decreased for average taxable profits realized for 2018, 2019, 2020 and 2021 increased for 20%. Assessment of average taxable profits for period 2018 to 2021 (inclusive) does not take into account year(s) during which tax losses were declared.
  • The solidarity contribution rate applicable to the tax base is 33%.
  • Solidarity contribution is self-assessed by taxpayers.
  • Deadlines for filling respective return and paying solidarity contribution are 30 June 2023 (for 2022 profits) and 30 June 2024 (for 2023 profits).

If you have any questions or you need assistance of our professionals, please contact us at tax@kpmg.rs.

For previous editions of KPMG Tax Alerts please visit the following web page:

KPMG Tax Alerts

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