The Ministry of Finance has adopted the
Instruction on Amendments to the Instruction on the Manner of Reporting Data by a Legal Entity that is a Member of a Group of International Related Legal Entities in Connection with Its Operations to the Tax Administration.
This amendment was published in the “Official Gazette of Montenegro”, No. 043/25 of May 7, 2025, and enters into force on the eighth day from the date of publication.
The new instruction more precisely regulates how legal entities from Montenegro, which are part of international groups of related legal entities, report on their operations to the Tax Authority. These are the so-called Country-by-Country Reports, which provide tax authorities with better insight into global revenues, profits, taxes, and other financial data within an international group.
The instruction specifically applies to members of international groups whose total consolidated income exceeds 750 million euros and who operate in multiple tax jurisdictions. It clarifies who is obligated to submit the report – whether it is the ultimate parent entity, a surrogate parent entity, or a Montenegrin member, depending on the circumstances and international agreements on the exchange of information.
Additionally, the amendments introduce further clarifications regarding situations in which reports are not required to be submitted, as well as the manner and deadlines for notifying the Tax Administration in cases of data non-submission, errors in the information exchange system, or other specific circumstances.
This amendment represents a step forward in strengthening tax transparency and aligning the domestic system with international standards prescribed by the OECD. It further regulates the obligations of economic entities and contributes to the global fight against tax avoidance.
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