Montenegro MOF Posts Draft Law to Implement Pillar 2 Global Minimum Taxation

December 2, 2025, 5:00 AM UTC

The Montenegrin Ministry of Finance Nov. 26 posted a draft bill to implement the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules. The bill includes measures to: 1) impose a 15 percent minimum tax on multinational and large domestic groups with at least 750 million euros (US$871.7 million) in annual revenue; 2) impose a qualified domestic minimum top-up tax (QDMTT), the income inclusion rule (IIR), and the undertaxed payments rule (UTPR); 3) require electronic tax returns within 18 months of the end of the fiscal year; 4) establish tax calculation rules, including adjustments for fiscal years longer or shorter than ...

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