Montenegro sets top-up-tax information-return filing rules

Which groups are affected

The rulebook implements Article 28(9) of the Global Minimum Tax Act, published in Official Gazette 33/2026, and Article 14k(6) of the Tax Administration Act. The minimum-tax law covers constituent entities of multinational and large domestic groups with consolidated revenue of at least €750 million in at least two of the four immediately preceding financial years, subject to statutory exclusions.^[1][2][3]

Central filing requires an agreement

Article 3 requires in-scope constituent entities to submit the information return. A local entity can instead rely on filing by its ultimate parent or designated filing entity where that entity’s jurisdiction has a qualifying competent-authority agreement with Montenegro effective for the reporting financial year. Where several group entities are located in Montenegro, the underlying legislation provides for a designated domestic filer.^[1][2][3]

Notification and fallback obligations

Article 4 requires notification identifying the filing entity and its jurisdiction 30 days before the return deadline. The notification renews automatically for subsequent years unless a new filer is appointed; a sole Montenegro constituent entity submits it only for the first year. If the identified entity does not submit the return, local filing obligations remain. Article 5 permits the tax authority to require local filing where the central-filing conditions are not met.^[1]

The statutory deadline is 18 months

Article 10 requires electronic submission in XML format using Form PIDP. The deadline comes from Article 28(6) of the minimum-tax law and Article 14k(3) of the Tax Administration Act: no later than 18 months after the financial year ends. The rulebook does not replace that statutory filing period.^[1][2][3]

Article 11 gives the tax authority three months after the return deadline to exchange the relevant information, extended to six months for the first reporting financial year. This is an authority-to-authority exchange period, not an additional filing extension for the group.^[1]

For multinational groups, central filing therefore needs both an eligible filing entity and the required agreement for the relevant year. Groups should establish those conditions, schedule the notification separately from the return, and retain a local fallback filing plan.^[1][2][3]