The Government of Montenegro has published the Draft Law on Amendments to the Law on Corporate Income Tax, which provides for the implementation of new rules against profit shifting in line with the EU Anti-Tax Avoidance Directive (ATAD) (Directive 2016/1164 as amended by Directive 2017/952). This includes:
- A 30% of EBITDA interest limitation rule, with a EUR 3 million de minimis threshold (safe harbor);
- New Controlled Foreign Company (CFC) rules for the taxation of undistributed profits ar…