Amendments to the Rulebook on the Implementation of the VAT Law: new rules for invoicing and taxpayer registration
The Ministry of Finance has adopted two important bylaws related to the implementation of value added tax (VAT) regulations:
- Rulebook on the Supplement to the Rulebook on the Implementation of the Law on Value Added Tax (“Official Gazette of Montenegro”, No. 145/25 of 11 December 2025),
- Rulebook on the Amendment to the Rulebook on the Implementation of the Law on Value Added Tax (“Official Gazette of Montenegro”, No. 008/26 of 23 January 2026).
These amendments introduce specific clarifications and improvements in the area of invoicing, as well as in the procedure for taxpayer registration, which is of particular importance for legal entities, entrepreneurs, and professionals in the fields of accounting and law.
New obligation to issue invoices in representation procedures
The supplement rulebook introduces a new Article 36a, which precisely defines the obligation to issue invoices in the process of representing clients before courts and other state authorities.
According to this article, the obligation to issue an invoice arises:
- on the basis of a power of attorney or a concluded contract with the client,
- ex officio, based on an enforceable decision on the costs of the procedure.
This amendment aims to further clarify the moment of occurrence of the tax liability in the provision of legal and similar services, where in practice there is often a deferred or specific method of payment.
For lawyers, legal representatives, and other providers of representation services, this provision brings greater legal certainty and clearer guidelines regarding the proper recording and taxation of income.
Amendments to the VAT registration procedure
The second rulebook introduces amendments to Article 132, which regulates the VAT taxpayer registration procedure. These amendments relate to the method of assigning the VAT number, as well as to the deadlines for action by the tax authority.
The most important changes include:
- automatic assignment of the VAT registration number by adding the prefix “ME” to the tax identification number (TIN),
- shortening the deadline within which the tax authority issues a registration decision from 15 to 7 days,
- confirmation that a person becomes a VAT taxpayer on the date determined in the decision,
- the obligation for a person who voluntarily registers for VAT to remain in the system for at least three years.
These amendments aim to accelerate administrative procedures and simplify the identification of VAT taxpayers, which is particularly important for new companies and entrepreneurs entering the VAT system.
Practical significance for taxpayers
The amendments and supplements to the rulebook have a direct impact on the daily operations of taxpayers. In practice, this means:
- more precisely defined invoicing obligations in specific activities,
- faster VAT registration and shorter waiting time for the decision,
- a more clearly defined VAT identification number,
- a higher level of compliance with tax regulations.
For accountants and tax advisors, these amendments represent an important basis for properly advising clients and aligning business operations with applicable legislation.
Entry into force
The Rulebook on the Supplement enters into force on the eighth day from the date of its publication in the “Official Gazette of Montenegro”, while the amendments from the second rulebook apply from the date of its entry into force, in accordance with its publication in January 2026.
The latest amendments to the Rulebook on the Implementation of the VAT Law bring important clarifications and improvements in the area of invoicing and taxpayer registration. Of particular importance is the introduction of Article 36a, which clearly regulates the obligation to issue invoices in representation procedures, as well as the acceleration of the VAT registration process.
Business entities and professionals should pay attention to these amendments in order to ensure proper application of regulations and avoid potential tax irregularities.
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