Which Countries Have a Tax Treaty with Montenegro?

Montenegro’s Double Tax Treaty Network: Which Countries Have a Treaty with Montenegro?
March 2026

At Ekonomik Accountants, we regularly advise foreign investors, international groups, expatriates and private clients on the practical use of double tax treaties. These treaties are important because they help prevent the same income from being taxed twice, allocate taxing rights between countries, and provide a clearer framework for dividends, interest, royalties, employment income, capital gains and permanent establishment questions.

A point that often causes confusion is that a significant part of Montenegro’s treaty network was originally concluded in the time of the former Yugoslavia, later the Federal Republic of Yugoslavia, or Serbia and Montenegro. That does not mean those treaties are invalid for Montenegro today. On the contrary, Montenegro continues to apply many of those legacy treaties as part of its current treaty network, which is also reflected in Montenegro’s OECD treaty notifications and in foreign government treaty references that expressly confirm continued application to Montenegro.

As a practical March 2026 working list, Montenegro’s treaty network covers the following countries: Albania, Andorra, Austria, Azerbaijan, Belarus, Belgium, Bosnia and Herzegovina, Bulgaria, China, Croatia, Cyprus, Czech Republic, Denmark, Egypt, Finland, France, Germany, Hungary, Iran, Ireland, Italy, Kuwait, Latvia, Luxembourg, Malaysia, Malta, Moldova, Monaco, Netherlands, North Korea, North Macedonia, Norway, Poland, Portugal, Romania, Russia, Serbia, Slovakia, Slovenia, Sri Lanka, Sweden, Switzerland, Turkey, Ukraine, United Arab Emirates, and the United Kingdom. This reflects the 44-country network publicly applied by Montenegro in late 2025, together with treaty-status updates showing Andorra and Luxembourg already in force by that time frame.

One of the more recent developments relevant as of March 2026 is that the treaty with Andorra entered into force on 1 July 2025, while the treaty with Luxembourg entered into force on 1 October 2025. By contrast, the treaty with Liechtenstein was signed on 25 September 2025, but had not yet entered into force as of March 2026, so it should be treated separately from the in-force treaty list. Montenegro also signed the BEPS Multilateral Instrument on 12 November 2025, which is an important treaty-modernisation step intended to update covered treaties, especially on anti-abuse and other OECD-aligned provisions. In parallel, Montenegro continued expanding its network through new negotiations, including the initialling of a treaty text with Iceland in July 2025.

In practice, however, the existence of a treaty is only the starting point. The real result depends on the specific article, the type of income, the residence status of the recipient, beneficial ownership, timing, treaty entitlement, and the available supporting documentation. This is why treaty analysis should always be done case by case, particularly for dividends, management fees, royalties, capital gains, cross-border services and group financing. For businesses and individuals active in Montenegro, the key message is clear: many of Montenegro’s treaties may be historic in origin, but generally they remain relevant and usable in modern cross-border structuring and tax compliance.