Montenegro Parliament Considers Bill to Implement Global Minimum Tax Rate Under OECD Pillar 2

The Montenegrin Parliament (Skupstina) Dec. 22 accepted for consideration Bill No. 16-2/25-7, to implement Directive 2022/2523/EU on the global minimum tax for multinational enterprise (MNE) and large domestic groups under OECD Pillar Two. The bill includes measures to: 1) impose a 15 percent minimum tax rate on resident constituent entities of groups with annual consolidated revenue of at least 750 million euros (US$883.2 million) in two or more of the last four fiscal years; 2) apply the qualified domestic minimum top-up tax (QDMTT), but not the income inclusion rule (IIR) or undertaxed payments rule (UTPR); 3) specify the profit and ...