🇲🇪 Montenegro
Europe & Central Asia · ISORA participant ·
Montenegro has implemented statutory country-by-country reporting requirements. The jurisdiction does not utilize automated bulk data matching for enforcement purposes. Additionally, Montenegro lacks controlled foreign company rules and interest limitation rules.Auto-generated summary of the verified data below; every fact traces to a source on this page.
6/11
enforcement powers assessed
Headline statutory rates
As stated in PwC Worldwide Tax Summaries’ territory overview (fetched 2026-08-20) — the wording is PwC’s; source.
| Tax | Headline rate as stated |
|---|---|
| Headline PIT rate | 15 |
| Headline CIT rate | 15 |
| Standard VAT rate | 21 |
| Headline individual capital gains tax rate | 15 |
| Headline corporate capital gains tax rate | 15 |
| WHT rates (%) (Dividends/Interest/Royalties) | Resident: 15 / NA / NA; Non-resident: 15 / 15 / 15; Non-resident in tax haven: 30 / 30 / 30 |
| Headline net wealth/worth tax rate | NA |
| Headline inheritance tax rate | 3 - 6 (payable only on inheritance of real estate) |
| Headline gift tax rate | 3 - 6 (payable only on real estate gifts) NA stands for Not Applicable (i.e. the territory does not have the indicated tax or requirement) NP stands for Not Provided (i.e. the information is not currently provided in this chart) |
Enforcement powers
Automated bulk data matching No — power absent
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration undertakes fully automated compliance checks based on data matching/analysis" — value: No”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Citizenship-based taxation No — power absent
Montenegro taxes individuals by residence, not citizenship (PwC Worldwide Tax Summaries).
“Resident individuals are subject to tax on their worldwide income from any source, whereas non-residents individuals are taxed on Montenegrin-sourced income.”
Source: PwC Worldwide Tax Summaries — MontenegroProfessional / legal analysis · quote machine-verified 2026-08-25
Controlled foreign company (CFC) rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there a controlled foreign company rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Interest limitation rules No — power absent
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (2026).
“OECD Corporate Tax Statistics: "Is there an interest limitation rule in place? · Not applicable" — No”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Country-by-country reporting Yes — statutory power
Recorded in the OECD Corporate Tax Statistics anti-avoidance rules dataset (0).
“OECD Corporate Tax Statistics: "Is there a country-by-country reporting law in place?" — Yes”
Source: OECD Corporate Tax StatisticsOECD / IMF survey data · derived from the administration’s own survey answer
Public naming of non-compliant taxpayers No — power absent
Self-reported to ISORA (International Survey on Revenue Administration), FY2022.
“ISORA indicator "Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure" — value: No”
Source: IMF ISORA — International Survey on Revenue AdministrationOECD / IMF survey data · derived from the administration’s own survey answer
Anti-avoidance regime detail (OECD Corporate Tax Statistics)
OECD-curated descriptions of this jurisdiction’s CFC, interest-limitation, CbCR and IP-regime rules.
CFC rules — 1 data points
| Is there a controlled foreign company rule in place? · Not applicable | No |
Interest limitation — 2 data points
| Is there an interest limitation rule in place? · Rule 1 | No |
| Is there an interest limitation rule in place? · Not applicable | No |
Country-by-country reporting — 4 data points
| Is there a country-by-country reporting law in place? | Yes |
| Deadline by which filings must be submitted | 12 months |
| Reports are required for MNEs with annual revenues above | EUR 750 million |
| Headquarter jurisidiction filing required from | 01-Jan-24 |
Administration self-reported metrics (ISORA)
Reported by the administration itself to the IMF/OECD/CIAT/IOTA International Survey on Revenue Administration. 1 = yes, 0 = no for policy questions.
| Indicator | Year | Value |
|---|---|---|
| Percentage of tax returns - Electronic, not prefilled - CIT | 2024 | 99.45164238481802 |
| Percentage of tax returns - Electronic, not prefilled - PIT | 2024 | 38.15162454873646 |
| Percentage of tax returns - Electronic, not prefilled - VAT | 2024 | 99.65458789342338 |
| Population per FTE | 2024 | 59.10749834107498 |
| Labor force per FTE | 2024 | 23.24078111669353 |
| Corporate taxpayers per FTE in LTO/P | 2024 | 19.28571428571429 |
| Active taxpayers on PIT register as percentage of Population | 2024 | 0.9492803015115673 |
| Active taxpayers on PIT register as percentage of Labor Force | 2024 | 2.414272720227437 |
| Closing stock of collectable arrears as percentage of closing stock of arrears | 2024 | 56.38723920696962 |
| CIT arrears as percentage of CIT collected | 2024 | 41.28700849911273 |
| PIT arrears as percentage of PIT collected | 2024 | 171.6106733029172 |
| PAYE arrears as percentage of PIT collected | 2024 | — |
| VAT arrears as percentage of VAT collected | 2024 | 12.1622389674202 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - CIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - PIT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled deemed acceptance - VAT | 2021 | 0 |
| Percentage of tax returns - Electronic, fully pre-filled confirmation required - VAT | 2021 | 0 |
| Percentage of tax returns - Electronic, partially pre-filled with income and/or expense information - VAT | 2021 | 0 |
| Additional assessments raised through all audits and verification actions as percentage of tax collections | 2024 | 3881.239263833834 |
| Audit hit rate | 2024 | 19.7092084006462 |
| Percentage of tax returns - Electronic, not prefilled - PAYE | 2024 | 96.076582486061 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, not modified by taxpayer - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - PAYE | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - PAYE | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled, modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled not modified by taxpayer - VAT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - CIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PIT | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - PAYE | 2024 | 0 |
| Percentage of tax returns - Electronic, prefilled Total - VAT | 2024 | 0 |
| Availability of specific powers in legislation / regulation to assist in collecting tax arrears | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Common administrative penalty framework for non-disclosure across the major tax types | 2022 | 1 |
| Administrative sanctions for taxpayer non-disclosure - Penalties imposed generally take account of taxpayers' culpability (i.e. degree of blame) | 2022 | 0 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to remit / reduce penalties in appropriate circumstances | 2022 | 0 |
| Administrative sanctions for taxpayer non-disclosure - Administration is empowered to make public details of some / all taxpayers subject to administrative penalties imposed for non-disclosure | 2022 | 0 |
| On-time filing rate % - CIT | 2024 | 81.79508477060634 |
| On-time filing rate % - PIT | 2024 | 116.5737455651292 |
| On-time filing rate % - VAT | 2024 | 77.4962989281696 |
| On-time filing rate % - PAYE | 2024 | 33.75002982083641 |
| Administration pre-fills PIT returns or assessments | 2024 | 0 |
| Administration conducts random audits | 2022 | 0 |
| E-filing mandatory - CIT | 2022 | 1 |
| E-filing mandatory - PIT | 2022 | 1 |
| E-filing mandatory - Employer Withholdings | 2022 | 1 |
| E-filing mandatory - VAT | 2022 | 1 |
| E-payment mandatory - CIT | 2022 | 0 |
| E-payment mandatory - PIT | 2022 | 0 |
| E-payment mandatory - Employer Withholdings | 2022 | 0 |
| E-payment mandatory - VAT | 2022 | 0 |
| Employers withholding taxes on behalf of salaried employees | 2024 | 1 |
| Percentage of payments received electronically-By number of payments | 2024 | — |
| Percentage of payments received electronically-By value of payments | 2024 | — |
| Cooperative compliance approach exists for -Large taxpayers | 2024 | 1 |
| Cooperative compliance approach exists for -HNWI taxpayers | 2024 | 0 |
| Cooperative compliance approach exists for -Other taxpayers | 2024 | 1 |
| Most employees that have tax deducted through direct withholding required to file a return | 2024 | 1 |
| Administration receives data from devices that register transactions | 2024 | 1 |
| Administration uses electronic compliance checks as part of returns filing process | 2024 | 0 |
| Administration has specialized audit staff for international tax issues | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Customs data | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from stock exchanges | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from the Social Security Agency | 2022 | 1 |
| Administration has systems for importing, storing and managing third-party data - Data from online (internet-based) vendors | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data from Utilities | 2022 | 0 |
| Administration checks the quality of data reported by third parties on a systematic basis | 2022 | 0 |
| Administration has systems for importing, storing and managing third-party data - Data on property ownership and sales | 2022 | 1 |
| Administration undertakes fully automated compliance checks based on data matching/analysis | 2022 | 0 |
| Administration measures the effectiveness of any compliance interventions undertaken | 2022 | 0 |
| Administration has standards for auditor productivity | 2022 | 0 |