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| 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