Montenegro: Montenegro and Portugal sign DTA

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

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 & shared bottom lb ros

More from across our site

Firms announced key tax partner hires across the US and UK, while fintech and software providers revealed board appointments and new tools for multinational tax teams
It continues a prolific spree of investment for the firm, after it launched in Indonesia, Thailand, Saudi Arabia and Japan in 2025
Booming APA statistics reflect the growing credibility of India’s TP framework and the country’s shift toward a tax certainty approach, ITR has heard
Partners at both firms have voted in favour of the tie-up, which marks ‘the largest law firm merger in history’
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
The combination between Ashurst and Perkins Coie, which will create a $2.8 bn law firm, is expected to close in Q3
The ‘highly regarded’ Stephanie Pantelidaki, who has big four experience, will be based in the firm’s London office
A co-operative working relationship with the UK tax agency has helped 'unblock entrenched positions' to the benefit of clients, Kara Heggs tells ITR
New hires from rivals are reportedly being axed from the firm, following a steep decline in profits
Gift this article