Montenegro committee backs Pillar Two bill proposing 15-month returns

Committee-stage milestone

The Committee on Economy, Finance and Budget reported on its 159th session of 5 November and recorded that MPs Seid Hadžić and Milan Zečević introduced the bill. The seven-vote recommendation asks Parliament to adopt the proposal. It is not a plenary vote, enacted amendment or Gazette publication.^[1]

Technical scope described

The report describes further alignment with EU Directive 2022/2523 and proposed clarifications to the tax base, allocation of top-up tax between constituent entities, entity location, and effective-tax-rate and top-up-tax calculations. The Government had supported the proposal on 2 October, and the sponsors announced amendments; neither the underlying filed bill nor those announced amendments was available in the reviewed sources.^[1]

Proposed filing periods

The report says the information return and the qualified domestic minimum top-up tax return would move from 18 to 15 months after the last day of the fiscal year. It says the 18-month period would remain for the law's first application year. The report does not identify that first year, so groups should not infer a live deadline or implementation period from the committee summary alone.^[1]

Existing-law perimeter

Montenegro's current global minimum corporate tax law applies to constituent entities in multinational and large domestic groups with consolidated revenue of at least €750 million in at least two of the four fiscal years before the reporting year. The Official Gazette records the current law as published and effective on 10 March 2026. The committee-stage proposal changes no current obligation until final passage, promulgation and commencement.^[1][2][3]

Monitor final text

Potentially in-scope groups should identify Montenegro constituent and filing entities, preserve their existing compliance calendars, and monitor the plenary text, sponsor amendments and Gazette publication. The detailed calculation changes, first application year, final return periods and commencement are separate verification gaps and do not prevent focused coverage of the committee milestone.^[1][2][3]