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

The ever-expansive firm has once again attracted a former ‘big four’ talent to lead the new offering
The amended double taxation avoidance agreement removes France’s most favoured nation status for tax treaty benefits
The levies extended beyond the president’s ‘legitimate reach’, the Supreme Court ruled
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment
The expanded firm will comprise roughly 8,500 employees, including 550 partners; in other news, Paul Hastings and Macfarlanes made senior tax hires
Meanwhile, one expert highlights the importance of separating Venezuela’s tax authority from direct political control after ‘lost decades and isolation’
With PMK 108, Indonesia has upgraded its tax transparency regime for the digital era, focusing on data quality, governance, and cross border exchange rather than expanding regulatory reach
In a popular LinkedIn post, Jeremie Beitel encouraged firms to invest in junior talent even if it doesn’t lead to their loyalty, though recruiters offered ITR a mixed assessment
Advisers who do not register for the new regime in time could be prevented from interacting with HMRC, the tax authority said
Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
Gift this article