Consolidated Tax Return Changes

Rulebook Amending the Rulebook on the Consolidated Tax Return

The Ministry of Finance has adopted the Rulebook Amending the Rulebook on the Consolidated Tax Return (“Official Gazette of Montenegro”, No. 108/25 of 26.09.2025).

This rulebook introduces amendments to the PD-KPP Form, the primary document used by groups of related legal entities when submitting a joint tax return. The goal of these amendments is to enhance transparency, accuracy, and efficiency in the calculation and reporting of corporate income tax within the consolidated system.

What do the amendments bring?

The new PD-KPP form introduces both technical and substantive improvements designed to simplify form completion and enable taxpayers to more easily comply with their legal obligations.

Key changes include:

• More precise reporting of group member data – taxpayers must now provide detailed information for each legal entity within the group, including tax identification number (PIB), legal name, and financial results.
• Improved profit and loss reporting model – a clearer method has been introduced for presenting consolidated profits and losses, avoiding double taxation and improving data transparency.
• Capital gains and losses – these must now be reported separately and linked to the group’s total results, with supporting documentation required to verify data accuracy.
• Refined calculation of the tax base and applicable rates, as follows:
  • 9% for profit up to €100,000,
  • 12% for profit between €100,000 and €1,500,000,
  • 15% for profit above €1,500,000.
• Guidelines for tax reliefs and deductions – the rulebook prescribes how to record tax credits, carried-forward losses, and foreign taxes paid.
• Digital adaptability of the form – the new format allows for easier electronic submission through the Revenue and Customs Administration’s system.

Importance of the amendments to the rulebook on the consolidated tax return for taxpayers

These amendments are particularly significant for large business systems and corporate groups operating through multiple legal entities. The consolidated tax return enables unified reporting of all income, expenses, gains, and losses within a group, providing a clearer overview of financial performance and reducing administrative burdens.

Furthermore, the new form enhances alignment with international accounting standards and tax transparency practices — an important step toward Montenegro’s European integration process.

Implementation and availability

This rulebook enters into force on the eighth day following its publication in the “Official Gazette of Montenegro”.

All tax obligations relating to periods after its entry into force must be reported exclusively using the new PD-KPP form.