Montenegro

Transfer Pricing in Montenegro

Montenegro transfer pricing for tax year 2026 under the Corporate Profit Tax Law (Articles 38 to 38c) and the Ministry of Finance instruction 121/22. Covers who is a related person (25% of shares, votes or profit, actual control, family members, and any company from a listed low-tax territory), the arm's-length rule and its upward-only adjustment, the seven pricing methods and their margin formulas, the 4.97% prescribed interest rate for related-party loans in 2026, the large-taxpayer criteria, the contents of full and shortened documentation, the EUR 75,000 shortened-file threshold, delivery with the return or within 45 days of a request, the 30 June transitional date, country-by-country reporting for groups with EUR 750 million revenue, fines and late-payment interest. Trigger phrases: transferne cijene, van dohvata ruke, povezana lica, Montenegro transfer pricing, related-party loan interest rate Montenegro, CbCR Montenegro.