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

While it’s great that the OECD is alive to multinationals’ fears of being caught in a compliance trap, the ‘common understanding’ illustrates a worrying lack of readiness
Rising demand for specialist expertise has fuelled the growth in tax partner headcounts, Cain Dwyer found; in other news, Switzerland has been urged to reconsider pillar two
An OECD report on the taxation of the digital economy is expected by the end of 2026, according to the group of nations
Trophy assets are evolving from personal indulgences to structured investments, prompting family offices to prioritise tax efficiency, governance discipline, and cross-border compliance
As demand for complex, cross-border private client counsel spikes, Patrick McCormick sees opportunity in starting from scratch
As part of an exclusive global alliance, KPMG will become one of Anthropic’s ‘preferred consultants’ for private equity
In the second part of this series, the focus shifts to how taxpayers can manage ongoing risks across the lifecycle of cross-border structures
Jurisdictions have moved to ensure that multinationals are not punished for late GIR filings due to a lack of available filing portals or exchange relationships
HMRC’s push for unified tax adviser registration won’t prevent every instance of improper conduct, but it is good for taxpayers and the UK’s reputation
Elsewhere, the UAE’s tax office has issued an update on registration penalties and two firms have been busy making lateral hires
Gift this article