Montenegro transfer pricing, tax year 2026

Who this applies to

Any corporate profit taxpayer in Montenegro that has one or more transactions with a related person, domestic or foreign. Dealings between a Montenegro permanent establishment (PE) and its nonresident head office are also controlled transactions and need documentation (CIT Law art. 38c(4)).

A person is related to the taxpayer if it takes part, directly or indirectly, in the taxpayer's management, control or capital, or if the same persons take part in both (art. 38(2)). Taking part means (art. 38(3) to (5)):

• holding at least 25% of the shares or ownership interests, directly or indirectly; or
• having actual ability to control business decisions, which exists where the person holds or controls at least 25% of the voting rights, has a right to at least 25% of the profit, or is a family member of the taxpayer (or related to a family member).
• Family members are blood relatives in the direct line, collateral relatives to the fourth degree, a spouse or unmarried partner, a same-sex life partner, in-laws to the second degree (even after the marriage ends), adopted children and their descendants.

Any nonresident legal person from a territory on the Ministry of Finance list under Article 29(5) and (6) is a related person whatever the ownership (art. 38(6)). The list has 46 territories, including Jersey, Guernsey, the Isle of Man, Gibraltar, the BVI, the Cayman Islands, Panama and Bahrain; check the list itself.

The 2026 law is the CIT Law consolidated through Official Gazette 88/24. The amending law 104/26 applies from 1 January 2027; its new chapter Xa (interest limitation at 30% of EBITDA or EUR 3,000,000, CFC rules, exit tax, hybrid mismatches), Article 38m (advance pricing agreements) and Article 40a (general anti-abuse rule) apply only from the day Montenegro joins the EU (104/26 arts. 15, 17, 19). None of them applies to 2026.

Rates, bands and thresholds

Item	Amount	Tax year	Source
Related by ownership	at least 25% of shares or interests, direct or indirect	2026	CIT Law art. 38(3)
Related by control	at least 25% of votes, or right to at least 25% of profit, or family member	2026	CIT Law art. 38(4) and (5)
Listed low-tax territory entity	always a related person	2026	CIT Law art. 38(6), 29(5) and (6); Ministry list
Arm's-length interest rate on related-party loans, credits and other financial instruments (prescribed route)	4.97%	2026 (applies from 1 January 2026)	Rulebook, Official Gazette 145/25, arts. 1 to 3; CIT Law art. 38b(2)
Large taxpayer: delivers documentation	with the CIT return, 3 months after year end	2026	CIT Law arts. 38c(1), 40(3)
Other taxpayers: hold documentation	at the return date; deliver within 45 days of receiving a request	2026	CIT Law art. 38c(2)
Transitional date for both groups	30 June of the following year, "until 2027"	to 2027	CIT Law art. 44b
Shortened documentation (non-large taxpayers only)	transactions with the related person not above EUR 75,000 in the year	2026	CIT Law art. 38c(3)
Large-taxpayer criteria (at least two of three)	public-revenue tax obligations above EUR 600,000 in the two preceding business years; turnover above EUR 10,000,000 in the two preceding business years; more than 50 employees	2026	Rulebook 31/17, arts. 2 and 3
Banks and insurers	large taxpayers regardless of the criteria	2026	Rulebook 31/17, art. 5
Industry analysis not needed	activity is not the main activity and gives less than 10% of total revenue	2026	TP Instruction 121/22, art. 10
TNMM comparables	weighted average over 3 to 5 years; arm's-length range is the interquartile range	2026	TP Instruction 121/22, art. 8
Country-by-country (CbC) group threshold	consolidated revenue at least EUR 750 million in the fiscal year before the reporting year	2026	CbC Instruction 69/22 and 43/25, point 9
CbC notification (role, or identity and residence of the reporting entity)	no later than the CIT return date for the previous fiscal year	2026	CbC Instruction, points 19 to 21
Notice that the parent did not supply CbC data	within 12 months of the end of the reporting fiscal year	2026	CbC Instruction, point 7
Loans from the company to an individual	15% withholding on the gross amount paid; the EUR 5,000 a year exclusion does not apply to related persons	2026	CIT Law art. 28a
Default interest between related persons	not deductible	2026	CIT Law art. 11(11)
Interest paid to nonresidents above the usual commercial rate	not deductible	2026	CIT Law art. 11(4)
CIT rates applied to the adjusted profit	9% to EUR 100,000; EUR 9,000 + 12% to EUR 1,500,000; EUR 177,000 + 15% above	2026	CIT Law art. 28
Fine, legal person (documentation not delivered or not held)	EUR 1,000 to 20,000	2026	CIT Law art. 42a(1)(3) and (4)
Fine, responsible person in the company	EUR 500 to 2,000	2026	CIT Law art. 42a(2)
Interest on unpaid or underpaid tax, 1 January to 17 July 2026	0.03% a day from the day after the due date	2026	Tax Administration Law art. 95
Interest on unpaid or underpaid tax, 18 July to 31 December 2026	5.4% a year (ECB main refinancing rate + 3 points, set each half-year)	2026	104/26 Tax Administration Law amendment arts. 20, 26; Tax Administration decision, 24 Jul 2026

The taxable base

The arm's-length rule

A taxpayer with related-party transactions must set its taxable profit on arm's-length terms: the conditions must not differ from those between unrelated persons in comparable transactions under comparable circumstances (art. 38a(1) and (2)). Where they do, the taxpayer (or the tax authority) adjusts the base (art. 38a(3)). The taxpayer adds (art. 38a(4)):

1. the positive difference between arm's-length income and booked income from the transaction; or
2. the positive difference between booked expense and arm's-length expense.

The adjustment only increases the base. There is no domestic route to a downward adjustment, and an upward adjustment on one transaction is not netted against a favourable price on another. The documentation's conclusion computes the adjustment per transaction (or per type of transaction) with each related person, then sums them by person (Instruction art. 10(1)(5)). The tax effect follows the progressive Article 28 rates on the whole adjusted profit; a TP adjustment is not taxed at a flat 15%.

Methods

The law lists seven methods (art. 38b(1); Instruction art. 3). Choose the one that fits the facts, after a functional analysis of the controlled transaction, the data available and the degree of comparability (Instruction art. 4). Transactions can be aggregated or split, with reasons.

Method	How it works (Instruction)
Comparable uncontrolled price (CUP)	Compare the controlled price with a price between unrelated parties (internal, or public data). Subject, contract terms, market conditions, substance and risks must be roughly the same; differences must be reliably quantified or immaterial (art. 5).
Cost plus	Costs of the transaction plus a gross markup. Markup = (sales revenue minus cost) / cost x 100. Cost bases and accounting policies must be consistent (art. 6).
Resale price	Resale price to an unrelated customer less a comparable gross margin. Margin = (sales minus cost of goods sold) / sales x 100. Less reliable where the reseller adds much value (art. 7).
Transactional net margin (TNMM)	Net operating profit over sales, operating costs or operating assets; gross profit over operating costs for intermediaries. Only income and costs linked to the transaction. Comparables as a weighted average over 3 to 5 years; the range is first to third quartile (art. 8).
Profit split	Where operations are so integrated that separate testing is not possible, or unique valuable IP prevents comparables. Split combined profit (or loss) by routine returns first, then the residual (art. 9).
Other method	Only where methods 1 to 5 cannot set the price (art. 38b(1)(6)).
Combination	Where needed (art. 38b(1)(7)).

A cost-plus markup is on cost; a resale margin is on sales. They are different percentages and are not interchangeable.

For comparables, use internal data first. If external data is needed, use Montenegrin data first; data from other countries can be used where Montenegrin data is not available, taking account of market differences (Instruction art. 10(3) and (4)).

Related-party financing

For loans, credits and other financial instruments between related persons, the Ministry prescribes the arm's-length rate by 31 December for the next year (art. 38b(2)). For 2026 it is 4.97% (Rulebook 145/25 art. 2; it applies from 1 January 2026 under art. 3). As an alternative, the taxpayer can price the interest with the general methods in Article 38b(1) (art. 38b(3)). Record which route is used for each instrument.

Apply the 4.97% rate to 2026 only, on the actual principal outstanding for the actual period. Compare booked interest with arm's-length interest separately for each instrument: excess interest expense of a borrower, or shortfall in interest income of a lender, goes into the base under Article 38a(4).

Other rules on related-party finance that sit outside the pricing test:

• default interest between related persons is not deductible (art. 11(11));
• interest paid to nonresidents above the usual commercial rate is not deductible (art. 11(4));
• a company paying out a loan to an individual withholds 15% of the gross amount; the exclusion for loans up to EUR 5,000 a year applies only to individuals who are not related persons (art. 28a(1) and (2)); the withholding is reported by the end of February for the previous year (art. 28a(3));
• withholding on interest paid to a nonresident lender is covered in the cross-border skill.

Large-taxpayer status

Status decides whether documentation is delivered with the return or only held. Under Rulebook 31/17 a legal person is a large taxpayer if it meets at least two of: fiscal capacity (total public-revenue tax obligations over the two business years before the year of determination) above EUR 600,000; turnover above EUR 10,000,000 over those two years; more than 50 employees (arts. 2 and 3). Banks and insurers are large taxpayers regardless (art. 5). A related person of a large taxpayer whose turnover is wholly or mainly with that large taxpayer can also be designated (art. 4). The tax authority notifies the taxpayer in writing when it gains or loses the status (art. 6). Use that notice, not the accounting size class.

Documentation content

Full documentation (Instruction art. 10(1)) has six parts:

1. group analysis: business, legal and organisational structure, shareholders, history, financial overview, business policy and changes from the previous period, and the related persons involved;
2. industry analysis: classification, market conditions, competitors, suppliers, customers, price and profit drivers, risks (not needed for an activity that is not the main activity and gives under 10% of revenue);
3. functional analysis: each type of transaction with each related person, written contracts and key terms, functions, assets, risks, and why transactions are aggregated or split;
4. method selection, with the reasons;
5. conclusion: the adjustment per transaction and per related person under art. 38a(4), and the total;
6. appendix: the data used for the arm's-length price or range, the comparables (domestic or foreign) and the data sources.

Shortened documentation (art. 38c(3); Instruction art. 10, last paragraph) is open only to taxpayers that are not large taxpayers, where transactions with that related person do not exceed EUR 75,000 in the year. It contains the description of the transaction, its value and the related person. The threshold is tested per related person per year. It changes the documentation, not the arm's-length rule.

Deadlines and filing

• CIT return (Form PD) and payment: within three months after the end of the tax period, electronically, with the income statement and balance sheet (art. 40(3), (4) and (6)). For a calendar 2026 year: 31 March 2027.
• Large taxpayers: deliver the TP documentation with the return (art. 38c(1)).
• Other taxpayers: hold the documentation when the return is filed and deliver it within 45 days of receiving the tax authority's request (art. 38c(2)). The 45 days run from receipt of the request.
• Transitional rule: until 2027, large taxpayers deliver, and other taxpayers must hold, the documentation by 30 June of the year after the year it covers (art. 44b). For the 2025 year that was 30 June 2026. The return and tax payment deadline is not moved.
• CbC reporting: see the next part.

Country-by-country reporting

The CbC instruction (Official Gazette 69/22 and 43/25) applies to members of an international group whose consolidated revenue was at least EUR 750 million in the fiscal year before the reporting year, with entities or PEs in more than one jurisdiction (point 9). For a group whose ultimate parent is outside Montenegro, currency fluctuation is handled under the OECD guidance published by the tax authority (point 9a).

• A Montenegrin ultimate parent or surrogate parent files the CbC report on the form attached to the instruction (points 3, 18).
• A Montenegrin member that is not the ultimate parent files only in the cases in point 4 (the parent has no filing duty at home; no competent-authority agreement in effect within 12 months of year end; a systemic failure notified by the tax authority). Until Montenegro meets the OECD minimum standards on appropriate use and confidentiality, a Montenegrin member other than the ultimate or surrogate parent does not file the report (point 2b). A surrogate parent abroad displaces local filing only if the point 16 conditions are met.
• Every Montenegrin member notifies the tax authority whether it is the ultimate parent, surrogate parent or another member, and, if it is not the reporting entity, the identity and tax residence of the reporting entity, no later than the CIT return date for the previous fiscal year (points 19 and 20). No new notice is needed until that identity or residence changes (point 21).
• A member that asks the parent for data and does not get it notifies the tax authority within 12 months of the end of the reporting fiscal year (points 6 and 7).

Form Table 1, per jurisdiction: revenue from unrelated parties, related parties and total (1.5a to c), profit before tax (1.6), income tax accrued for the current year (1.7), income tax paid (1.8), stated capital (1.9), accumulated earnings (1.10), employees (1.11), tangible assets (1.12). Table 2 lists each member by jurisdiction with its main activities; Table 3 is additional information. Form instructions:

• revenue excludes payments from other group members that are dividends in the payer's jurisdiction (instruction 2);
• profit before tax includes extraordinary items (4);
• accrued tax is current-year tax only, without deferred or contingent tax (6);
• tax paid is tax actually paid in the year, in the home jurisdiction and elsewhere, including withholding paid by others on payments to the member (7 to 9);
• tangible assets are net book values excluding cash, intangibles and financial assets (16);
• PE data go to the PE's jurisdiction (17; points 25 and 26);
• use the same data sources each year and explain any change (points 28 and 29); members with a different fiscal year report the year ending within the 12 months before the reporting entity's year end (point 27).

Penalties and interest

Under CIT Law Article 42a, a legal person is fined EUR 1,000 to 20,000, and the responsible person in it EUR 500 to 2,000, where it:

• as a large taxpayer, does not deliver TP documentation with the return (art. 42a(1)(3));
• as another taxpayer, does not hold the documentation at the return date and does not deliver it within 45 days of a request (art. 42a(1)(4));
• does not compute CIT under the law (art. 42a(1)(5)), or does not file the return electronically within three months (art. 42a(1)(6)).

Tax underpaid because of a TP adjustment carries interest at 0.03% a day until 17 July 2026 and, from 18 July 2026, at 5.4% a year (ECB main refinancing rate plus 3 points, set each half-year; 104/26 arts. 20 and 26 and the Tax Administration decision of 24 July 2026), from the day after the due date (Tax Administration Law art. 95(1)); there is no interest on interest (art. 95(7), art. 95(3) before 104/26). Overpaid tax earns interest at the same rate (art. 96(1)). Until 17 July 2026 that interest ran from the day the refund claim was received; from 18 July 2026 art. 96(2) says interest is calculated within 30 days of receipt of the claim (104/26 art. 21). Appeals and enforcement follow the tax procedure law (CIT Law art. 42).

Cross-border points

• A nonresident from a listed low-tax territory is a related person for TP even with no ownership link (art. 38(6)); payments to it also bear 30% withholding where Article 29(5) applies. See the cross-border skill.
• PE and head-office dealings are documented like any controlled transaction (art. 38c(4)). Administrative costs a PE pays to its nonresident head office are not deductible at all (art. 11(5)).
• There is no domestic procedure for a corresponding (downward) adjustment where a foreign authority raises the price on the other side. Relief, if any, comes through the mutual agreement article of the applicable tax treaty. The EU Arbitration Convention will apply only after EU accession (104/26 art. 18).
• Interest limitation, CFC, exit and hybrid rules (104/26 chapter Xa) and advance pricing agreements (art. 38m) are not in force for 2026 and start only on EU accession.

Worked examples

All amounts in EUR. Each example assumes the related-party status and the method choice are already established, and that the benchmark figures come from a supported comparables study.

1. CUP and understated sales

A comparable uncontrolled price, after documented adjustments, supports 52 per unit for 10,000 units sold to a related person. The booked price is 49. Booked revenue is 490,000; arm's-length revenue is 520,000. The positive difference of 30,000 is added to the base (art. 38a(4)(1); Instruction art. 5).

name: Montenegro CUP upward income adjustment
inputs:
  units: 10000
  booked_unit_price: 49
  supported_unit_price: 52
steps:
  - booked_revenue: units * booked_unit_price
  - arm_length_revenue: units * supported_unit_price
  - upward_base_adjustment: max(0, arm_length_revenue - booked_revenue)
expected:
  booked_revenue: 490000
  arm_length_revenue: 520000
  upward_base_adjustment: 30000

2. Cost-plus service pricing

A service provider's comparable cost base is 200,000 and the supported gross markup on cost is 8%. Arm's-length revenue is 200,000 + 16,000 = 216,000. Booked revenue is 210,000, so 6,000 is added to the base (Instruction art. 6; art. 38a(4)(1)).

name: Montenegro cost plus denominator and income adjustment
inputs:
  comparable_cost_base: 200000
  supported_markup_on_cost: 0.08
  booked_service_revenue: 210000
steps:
  - supported_gross_profit: comparable_cost_base * supported_markup_on_cost
  - arm_length_revenue: comparable_cost_base + supported_gross_profit
  - upward_base_adjustment: max(0, arm_length_revenue - booked_service_revenue)
expected:
  supported_gross_profit: 16000
  arm_length_revenue: 216000
  upward_base_adjustment: 6000

3. Resale margin and excessive purchase cost

A distributor resells goods to independent customers for 500,000. The supported gross margin is 20% of sales, so the arm's-length cost of goods is 500,000 - 100,000 = 400,000. The related-party purchase cost booked as expense is 430,000. The excess expense of 30,000 is added to the base (Instruction art. 7; art. 38a(4)(2)). Using 20% on cost instead would give a different, wrong answer.

name: Montenegro resale margin expense adjustment
inputs:
  unrelated_resale_revenue: 500000
  supported_margin_on_sales: 0.20
  booked_related_goods_expense: 430000
steps:
  - supported_gross_profit: unrelated_resale_revenue * supported_margin_on_sales
  - arm_length_goods_expense: unrelated_resale_revenue - supported_gross_profit
  - upward_base_adjustment: max(0, booked_related_goods_expense - arm_length_goods_expense)
expected:
  supported_gross_profit: 100000
  arm_length_goods_expense: 400000
  upward_base_adjustment: 30000

4. TNMM weighted comparable margin

One comparable company has operating profit of 30, 100 and 90 on sales of 1,000, 2,000 and 3,000 over three years. The weighted margin is 220 / 6,000 = 3.67%, not the simple average of the three yearly margins (3.0%, 5.0%, 3.0%). Repeat for each comparable, then take the interquartile range (Instruction art. 8).

name: Montenegro TNMM weighted sales denominator
inputs:
  profit_year_1: 30
  profit_year_2: 100
  profit_year_3: 90
  sales_year_1: 1000
  sales_year_2: 2000
  sales_year_3: 3000
steps:
  - combined_profit: profit_year_1 + profit_year_2 + profit_year_3
  - combined_sales: sales_year_1 + sales_year_2 + sales_year_3
  - weighted_margin_percent: combined_profit / combined_sales * 100
expected:
  combined_profit: 220
  combined_sales: 6000
  weighted_margin_percent: 3.6666666667

5. Related-party loan priced under the general methods

A 300,000 loan from a related lender is outstanding all year at 8%. The borrower elects the general-method route (art. 38b(3)) and a supported study sets the arm's-length rate at 6%. Booked interest 24,000 less arm's-length interest 18,000 gives 6,000 added to the base.

name: Montenegro hypothetical loan pricing adjustment
inputs:
  principal: 300000
  booked_rate: 0.08
  supported_general_method_rate: 0.06
steps:
  - booked_interest: principal * booked_rate
  - arm_length_interest: principal * supported_general_method_rate
  - upward_base_adjustment: max(0, booked_interest - arm_length_interest)
expected:
  booked_interest: 24000
  arm_length_interest: 18000
  upward_base_adjustment: 6000

6. Prescribed 2026 rate: borrower

A related-party loan of 300,000 is outstanding for all of 2026 at 8%. The borrower uses the prescribed 4.97% rate. Booked interest 24,000 less priced interest 14,910 gives 9,090 added to the base (art. 38a(4)(2), 38b(2); Rulebook 145/25 art. 2).

name: Montenegro 2026 prescribed borrower interest
inputs:
  full_year_principal: 300000
  booked_rate: 0.08
  prescribed_2026_rate: 0.0497
steps:
  - booked_expense: full_year_principal * booked_rate
  - priced_expense: full_year_principal * prescribed_2026_rate
  - positive_base_adjustment: max(booked_expense - priced_expense, 0)
expected:
  booked_expense: 24000
  priced_expense: 14910
  positive_base_adjustment: 9090

7. Prescribed 2026 rate: lender

A Montenegro lender has a related-party loan of 300,000 outstanding for all of 2026 at 2%. At 4.97%, interest income would be 14,910 against 6,000 booked, so 8,910 is added to the base (art. 38a(4)(1)). This is a separate loan from example 6; the two are not netted.

name: Montenegro 2026 prescribed lender interest
inputs:
  full_year_principal: 300000
  booked_rate: 0.02
  prescribed_2026_rate: 0.0497
steps:
  - booked_income: full_year_principal * booked_rate
  - priced_income: full_year_principal * prescribed_2026_rate
  - positive_base_adjustment: max(priced_income - booked_income, 0)
expected:
  booked_income: 6000
  priced_income: 14910
  positive_base_adjustment: 8910

8. CbC report, Table 1 figures for one jurisdiction

An in-scope group's members in one jurisdiction have unrelated revenue of 100 million and receipts from group members of 45 million, of which 5 million are dividends. Tax expense of 2.1 million includes 0.3 million deferred tax. Tax actually paid in the year is 1.0 million for the current year, 0.4 million for an earlier year and 0.2 million withheld by payers on payments to the members. Total assets are 30 million, including cash 5 million, intangibles 3 million and financial assets 2 million. No PEs and no currency conversion.

Related revenue is 45 - 5 = 40 million; total revenue 140 million. Accrued current tax is 2.1 - 0.3 = 1.8 million. Tax paid is 1.0 + 0.4 + 0.2 = 1.6 million. Tangible assets are 30 - 5 - 3 - 2 = 20 million (form instructions 2, 6 to 9, 16). The 140 million is this jurisdiction's revenue for the form, not the EUR 750 million group test, which uses the prior year's consolidated revenue.

name: Montenegro CbCR jurisdiction revenue tax and tangible assets
inputs:
  unrelated_revenue: 100000000
  related_receipts: 45000000
  excluded_dividends: 5000000
  tax_expense_including_deferred: 2100000
  deferred_tax: 300000
  current_tax_paid: 1000000
  prior_period_tax_paid: 400000
  qualifying_withholding_paid: 200000
  total_assets: 30000000
  cash: 5000000
  intangibles: 3000000
  financial_assets: 2000000
steps:
  - related_revenue: related_receipts - excluded_dividends
  - total_reported_revenue: unrelated_revenue + related_revenue
  - current_accrued_tax: tax_expense_including_deferred - deferred_tax
  - total_paid_tax: current_tax_paid + prior_period_tax_paid + qualifying_withholding_paid
  - tangible_assets: total_assets - cash - intangibles - financial_assets
expected:
  related_revenue: 40000000
  total_reported_revenue: 140000000
  current_accrued_tax: 1800000
  total_paid_tax: 1600000
  tangible_assets: 20000000

Ask the client first

1. Who owns and controls the company, directly and indirectly, and which counterparties share owners, managers or family members with it? Is any counterparty incorporated, seated or managed in a listed territory?
2. Has the tax authority sent a written notice that the company is a large taxpayer (or that it lost the status)? Is it a bank or insurer?
3. What is the total 2026 value of transactions with each related person, by type (goods, services, loans, IP, PE and head-office charges)?
4. For each related-party loan: principal movements, dates, booked rate, and whether the company uses the prescribed 4.97% rate or its own study?
5. Is the company in a group with consolidated revenue of at least EUR 750 million in the previous fiscal year? If so, which entity is the ultimate parent, where is it resident, and who files the CbC report?
6. Does a foreign related party or tax authority expect a matching adjustment on its side?

Sources

Source	URL	Read on
Corporate Profit Tax Law (Zakon o porezu na dobit pravnih lica), Ministry of Finance consolidated text through Official Gazette 88/24, arts. 3, 4, 11, 28, 28a, 29, 38 to 38c, 40, 42, 42a, 44b, 45a	https://wapi.gov.me/download/8826962a-3806-4619-afa4-0029b0a57afb?version=1.0	2026-10-30
Law amending the Corporate Profit Tax Law, Official Gazette 104/26, arts. 1, 8, 15 (arts. 38d to 38m), 16 (art. 40a), 17, 18, 19	https://wapi.gov.me/download/8951908b-625c-4219-aefe-0c86501ddaf8?version=1.0	2026-10-30
Instruction on determining transfer prices, Official Gazette 121/22, arts. 3 to 10	https://wapi.gov.me/download/8687197d-36c9-475c-aabe-5718e8312653?version=1.0	2026-10-30
Rulebook on the interest rate on financial instruments between related persons for 2026, Official Gazette 145/25, arts. 1 to 3	https://www.sluzbenilist.me/propisi/388766/download	2026-10-30
Rulebook on criteria for large taxpayers, Official Gazette 31/17 (Ministry of Finance publication, April 2026), arts. 2 to 6	https://wapi.gov.me/download/25b068f5-3b63-4397-9026-b0c270eaeb55?version=1.0	2026-10-30
Instruction on reporting by members of international groups (CbC), Official Gazette 69/22 and 43/25, points 2 to 29 and the attached form and instructions	https://wapi.gov.me/download/194f36b9-b629-4bfc-87f4-d0385517846f?version=1.0	2026-10-30
Ministry of Finance, list of territories with tax sovereignty under CIT Law art. 29 (published 28 March 2025)	https://wapi.gov.me/download/10ea79a6-8f36-463d-ab8c-b88ab655b61c?version=1.0	2026-10-30
Tax Administration Law (Zakon o poreskoj administraciji), consolidated text through Official Gazette 160/25 (before 104/26), arts. 95 and 96	https://wapi.gov.me/download/6bf4fd6a-fa32-4c33-9f5a-3a13ae509233?version=1.0	2026-10-30
Tax Administration Law, Ministry consolidated text through Official Gazette 104/26, arts. 95 and 96	https://wapi.gov.me/download/8e3ee8d0-f10c-453a-90ad-6439ac07aca2?version=1.0	2026-10-30
Law amending the Tax Administration Law, Official Gazette 104/26 (17 July 2026), arts. 20 (new art. 95 rate: ECB + 3 points), 21 (new art. 96) and 26 (in force the next day)	https://wapi.gov.me/download/c22f3c59-7e52-4213-bbe4-3cd9d8d3a373?version=1.0	2026-10-30
Tax Administration decision on the default interest rate for 18 July to 31 December 2026 (5.4% a year), 24 July 2026	https://wapi.gov.me/download/6d6ec964-3dd6-4588-b81a-a5affc153f6e?version=1.0	2026-10-30

Not yet confirmed: whether the Article 44b transitional date ("until 2027") covers 2026 documentation, giving 30 June 2027, or ends with 2025 documentation; whether Montenegro now meets the OECD appropriate-use and confidentiality standards that switch on local CbC filing by non-parent members (CbC point 2b); the deadline and electronic format for filing a full CbC report (the instruction sets none); which lines of Form PD and attachment carry the TP adjustment; whether interest on a refund runs from the day of the claim or from day 30 under the new art. 96(2); rules for intangibles, guarantees, cash pools and business restructurings beyond the general methods.

Contributed by Michael Cutajar.