Montenegro Gazettes Law Implementing Global Minimum Tax Rate Under OECD Pillar 2

The Montenegrin Official Gazette March 10 published Law No. 01-009/26-377/2, implementing Directive 2022/2523/EU on the global minimum tax for multinational enterprise (MNE) and large domestic groups under OECD Pillar Two. The law includes measures: 1) imposing a 15 percent minimum tax rate on resident constituent entities of groups with annual consolidated revenue of at least 750 million euros (US$863.8 million) in two or more of the last four fiscal years; 2) applying the qualified domestic minimum top-up tax (QDMTT), but not the income inclusion rule (IIR) or undertaxed payments rule (UTPR); 3) specifying the profit and loss calculations for ultimate ...