Montenegro MOF Posts Bill to Amend Corporate Income Tax Act

The Montenegrin Ministry of Finance April 23 posted a bill to amend the Corporate Income Tax Act. The bill includes measures to: 1) allow deductions for excess borrowing costs of up to 30 percent of taxable earnings before interest, taxes, depreciation, and amortization (EBITDA) or 3 million euros (US$3.5 million), whichever is higher; 2) tax the undistributed profits of specified controlled foreign corporations (CFCs) and permanent establishments (PEs) in low-tax jurisdictions; 3) impose exit tax on transfers between related parties, with a five-year deferral for transfers to EU or European Economic Area (EEA) countries; 4) deny or limit deductions for ...