Montenegro: Montenegro and Portugal sign DTA

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Montenegro: Montenegro and Portugal sign DTA

petrovic.jpg

Ivan Petrovic

Montenegro has signed double taxation treaties (DTAs) with more than 35 countries, and this number continues to grow.

The most recently signed treaty is the one concluded with Portugal. The agreement affects individuals who are residents of one or both of the contracting states and applies to the Portuguese personal income tax, corporate tax and surtax, as well as to the Montenegrin personal income tax and corporate tax.

The agreement stipulates that dividends paid by a resident of one contracting state to a resident of the other contracting state may be taxed in that other country. The withholding tax rate for dividends is defined to be 5% of a dividend's gross amount if the beneficial owner is a company that has a minimum 5% capital of the company that pays the dividend, or 10% in all other cases.

Interest that arises in one contracting state and is paid to a resident of the other contracting state may be taxed in that other state, but can also be taxed in the country in which it arises if the beneficial owner of the interests is a resident of that state. In such cases, the withholding tax rate is 10%.

As far as royalties are concerned, the withholding tax rate is 5% for royalties related to art, scientific or literary works, and 10% of gross amount for royalties related to trademark, design or model, plan, a secret formula or its procedure.

The treaty requires ratification by both countries before it enters into force.

Ivan Petrovic (ivan.petrovic@eurofast.eu)

Eurofast Montenegro

Tel: +382 20 228 490

Website: www.eurofast.eu

more across site & bottom lb ros

More from across our site

ITR’s most interesting stories of the year covered ‘landmark’ legal battles, pillar two, AI’s relationship with transfer pricing and more
Chinwe Odimba-Chapman was announced as Michael Bates’ successor; in other news, a report has found a high level of BEPS compliance among OECD jurisdictions
The tool, which will automatically compute amount B returns, requires “only minimal data inputs”, according to the OECD
The rules are intended to implement the substance of an earlier OECD report in its entirety
While new technology won’t replace the human touch, it could help relieve companies’ staffing issues, EY’s David Helmer and Daren Campbell tell ITR
The firm said the financial growth came from increased demand for its AI services and global tax reform advice
Chrystia Freeland had also been the figurehead of Canada’s controversial digital services tax adoption, which stoked economic tensions with the US
Panama has no official position on pillar two so far and a move to implement in Costa Rica will face rejection, experts tell ITR
The KPMG partner tells ITR about Sri Lanka’s complex and evolving tax landscape, setting legal precedents through client work, and his vision for the future of tax
Overall turnover at the firm also reached a record £8 billion; in other news, Ashurst and Dentons announced senior tax partner hires
Gift this article