New Global Minimum Tax Law — but it only touches giant groups above €750 million
TLDR
- Adopted by Parliament on 27 Feb 2026, published in Off. Gazette 033/26 of 10 Mar 2026 — in force from publication.
- Applies only to constituent entities of multinational enterprise groups or large domestic groups with at least €750,000,000 in consolidated revenue in 2 of the last 4 fiscal years.
- The minimum tax rate is 15% — if the effective rate in Montenegro is lower, a top-up tax is charged on the difference.
- Filing and payment deadline: 18 months after the fiscal year ends; penalties €3,000-40,000 per entity.
- DOES NOT APPLY to ordinary small and medium enterprises — the standard corporate tax rates (9/12/15%) stay unchanged for everyone else.
On 27 February 2026 Montenegro's Parliament adopted the Law on Global Minimum Tax on Corporate Profit, transposing the OECD/G20 Pillar Two framework into domestic law. The law was published in Official Gazette of Montenegro No. 033/26 of 10 March 2026 and entered into force on the day of publication.
The law introduces a top-up tax designed to ensure large groups pay at least a 15% effective profit tax rate in every jurisdiction where they operate. If a group's effective tax rate in Montenegro falls below 15%, the shortfall is collected as a top-up (global minimum) tax, with the revenue going to the state budget.
Scope is the key point: the law applies only to constituent entities of multinational enterprise groups or large domestic groups whose ultimate parent's consolidated revenue was at least €750,000,000 in at least two of the four fiscal years preceding the reporting year. Exemptions cover government entities, pension and investment funds, and non-profit organisations.
In-scope taxpayers must electronically file and pay within 18 months after the fiscal year ends, with a transitional period (2026-2032) phasing down the substance-based income exclusion. Penalties for non-compliance range from €3,000 to €40,000 for the entity, and €500 to €4,000 for the responsible individual.
In practice: for the vast majority of entrepreneurs and small and medium businesses in Montenegro, nothing changes — the standard corporate tax brackets (9/12/15%) remain fully in force. The law is relevant only to the finance teams of the (few) local subsidiaries of giant multinational groups with over €750 million in global revenue.