Montenegro: Implementation of Pillar Two global minimum tax rules
The law is expected to apply from January 1, 2026.
April 22, 2026
The law implementing a 15% domestic minimum top-up tax (DMTT) was published in the official gazette on March 10, 2026.
Key takeaways include:
- DMTT: Montenegro has opted to implement only a DMTT. The income inclusion rule (IIR) and undertaxed profits rule (UTPR) are not included in the domestic legislation.
- Safe harbor: The law includes a placeholder safe harbor provision allowing top-up tax to be deemed zero where the effective level of taxation fulfills the conditions of a “qualifying international agreement on safe harbors.”
- Application of OECD guidance: The law includes a dynamic reference clause requiring interpretation of the rules in line with the OECD commentary.
- Compliance: In‑scope entities are required to file their global anti-base erosion (GloBE) information return (GIR) and local DMTT returns electronically within 18 months following the end of the relevant fiscal year, deviating from the standard 15‑month GIR filing deadline under the GloBE rules (for tax years other than the first years in which an in-scope group files the GIR return, for which an 18-month deadline is available).
The law is expected to apply from January 1, 2026.
Read an April 2026 report prepared by KPMG’s EU Tax Centre