Non-Resident Withholding Tax in Montenegro (Porez po Odbitku)
Payments made to foreign non-resident legal entities without a permanent establishment in Montenegro are subject to withholding tax under Article 29 of the Law on Corporate Profit Tax:
- Statutory Flat 15.0% Rate: Applies to payments of:
- Dividends and profit distributions.
- Loan interest.
- Royalties, copyright, and patent licensing rights.
- Market research, consulting, and management services.
- Double Tax Treaties (DTT): Montenegro has active bilateral tax treaties with over 45 partner countries that may eliminate or reduce this rate upon submission of an authenticated foreign tax residency certificate.
Statutory Regulatory Framework: Compliant with the Law on Personal Income Tax (Evropa Sad), Law on Corporate Profit Tax, Labor Law of Montenegro, and regulatory decrees issued by the Revenue and Customs Administration (UPC) and REGAGEN.