How corporate tax works in Montenegro
Montenegrin resident companies are generally taxed on worldwide profit. A non-resident is taxed on Montenegrin-source income or profit attributable to a permanent establishment in Montenegro. Place of effective management can also affect residence for a foreign-incorporated company.
The corporate tax is progressive by taxable profit: 9% up to EUR 100,000; EUR 9,000 plus 12% of the amount above EUR 100,000 up to EUR 1.5 million; and EUR 177,000 plus 15% of the amount above EUR 1.5 million.
The 2026 global-minimum-tax law targets multinational and large domestic groups with consolidated revenue of at least EUR 750 million and can require a top-up to a 15% effective rate. Companies also need to model VAT, payroll, withholding tax, transfer pricing and e-invoicing compliance.
Tax rates at a glance
- Profit up to EUR 100,000
- 9%First band
- Profit EUR 100,000.01-1.5m
- EUR 9,000 + 12%
- Profit above EUR 1.5m
- EUR 177,000 + 15%
- Global minimum tax
- 15%In-scope groups
- Standard dividend WHT
- 15%
Who benefits most
These profiles tend to benefit most when the rules match their real residence, payroll and business setup.
FoundersHolding companiesRegional operatorsTourism businessesForeign investors
Watch out for
- A 9% starting rate does not mean every company pays 9% on every euro of profit. The tax is calculated progressively, and the global minimum-tax rules can change the answer for large groups.
- A foreign company can create Montenegrin tax exposure through a permanent establishment or place of effective management even if it was incorporated elsewhere.
- Payments to non-resident companies can trigger withholding tax, with treaty relief depending on residence documentation and beneficial ownership. Payments to listed low-tax territories can face a higher anti-abuse rate.
- The eight-year corporate-tax exemption available to qualifying newly established production businesses in underdeveloped municipalities is incentive-specific and capped, so it should not be treated as a general company holiday.
Frequently asked questions
What is Montenegro's corporate tax rate?
Montenegro applies progressive corporate tax rates of 9% up to EUR 100,000 of taxable profit, 12% in the middle band and 15% above EUR 1.5 million, using fixed-plus-marginal calculations for the upper bands.
Does Montenegro have a global minimum tax?
Yes. A 2026 law introduces a 15% minimum-tax framework for multinational and large domestic groups with consolidated revenue of at least EUR 750 million.
Are foreign companies taxed in Montenegro?
Yes, when they have Montenegrin-source income or a Montenegrin permanent establishment. A foreign company's effective management and treaty position also need to be reviewed.