Montenegro · Official Gazette of Montenegro 145/2025
Arm's length interest rate for 2026 in Montenegro: 4.97%
For 2026, the interest rate on borrowings, loans, credits and other financial instruments between related parties is 4.97%. It is set by a Ministry of Finance rulebook (Official Gazette of Montenegro 145/2025) and applies from 1 January 2026.
We reply on the next working day. We name the fee in writing, in our reply to your inquiry. Scope and timing are confirmed in writing before work starts.
In short
The arm's length interest rate for 2026 in Montenegro is 4.97% (Art. 2 of the Ministry of Finance rulebook, Official Gazette of Montenegro 145/2025).
It is charged on borrowings, loans, credits and other financial instruments between related parties for 2026, and applies from 1 January 2026.
The rulebook was adopted under Art. 38b(2) of the Corporate Income Tax Law.
01Guide
What the 2026 rulebook sets
The Ministry of Finance adopted the Rulebook on the interest rate charged on financial instruments between related parties for 2026 under Art. 38b(2) of the Corporate Income Tax Law. Art. 1 sets the interest rate that, in line with the arm's length principle, is charged on borrowings, loans, credits and other financial instruments between related parties for 2026; Art. 2 sets it at 4.97%.
Rate: 4.97% (Art. 2).
Year: 2026 (Art. 1).
Adopted on 4 December 2025, published in the Official Gazette of Montenegro 145/2025 on 11 December 2025.
In force from 19 December 2025 (the eighth day after publication), applying from 1 January 2026 (Art. 3).
02Guide
What to watch
The rulebook sets a single rate, without a split by currency or maturity. In Serbia, the 2026 rulebook sets separate rates by currency and maturity.
The year of calculation matters: 4.97% is the rate set for 2026.
Where the terms of a loan depart from the usual ones (currency, term, collateral, the borrower's credit rating), we document the market rate with a benchmark under the OECD Guidelines (Chapter X).
IVMethodology
The year of calculation matters: 4.97% is the rate set for 2026.
What to watch
VIFee
Intercompany interest rate benchmark
For loans whose terms depart from the usual ones, we document the market rate with a benchmark.
from €1,800
Intercompany interest rate benchmark · Timing is confirmed in writing before work starts, with the scope.
Scope, timing and fee are confirmed in writing before work starts. What is not included is listed in the written offer.
VIISources and legal framework
Primary sources for this page
Content prepared and checked by the Schule d.o.o. Podgorica team. The sources are in Montenegrin; this page is general information, not advice for a specific case.
Updated Sources checked
- Rulebook on the interest rate charged on financial instruments between related parties for 2026, Official Gazette of Montenegro 145/2025 (in Montenegrin)
- Corporate Income Tax Law, consolidated text (gov.me, in Montenegrin)
- Serbia: Rulebook on arm's length interest rates for 2026, Official Gazette of the Republic of Serbia 36/2026 (in Serbian)
- OECD Transfer Pricing Guidelines (2022)
VIIIQuestions
Questions clients ask about this topic
What is the arm's length interest rate for 2026 in Montenegro?
4.97%, under Art. 2 of the Rulebook on the interest rate charged on financial instruments between related parties for 2026 (Official Gazette of Montenegro 145/2025).
Which transactions does the rate apply to?
Borrowings, loans, credits and other financial instruments between related parties, for 2026 (Art. 1 of the rulebook).
From when does it apply?
From 1 January 2026. The rulebook was published on 11 December 2025 and entered into force on the eighth day after publication (Art. 3).
Inquiry
Tell us about your related parties and transactions
IXNext step
Describe your related parties and transactions: we reply on the next working day
We reply on the next working day. We name the fee in writing, in our reply to your inquiry. Scope and timing are confirmed in writing before work starts.