BEPS Action 13 · CbC MCAA · €750 million threshold
CbC reporting in Montenegro: obligations from 2024
Country-by-Country reporting is one of the largest BEPS reforms. The Montenegrin member of a multinational group files a notification, and the report itself is filed by the ultimate (or surrogate) parent company.
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
CbC reporting applies from fiscal years starting on 1 January 2024 for groups with at least €750 million of consolidated revenue.
No later than the day it files its corporate income tax return, the Montenegrin group member notifies the Tax Administration who files the report; local filing of the report itself is suspended.
The report itself is filed by the ultimate (or surrogate) parent company within 12 months of the end of the reporting year; Montenegro signed the CbC MCAA on 14 May 2024.
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Who must file a CbC report
Multinational groups with at least €750 million of consolidated revenue in the previous fiscal year are obliged, for fiscal years starting on or after 1 January 2024. The report is filed by the ultimate parent company, or by the surrogate parent company where one is designated, within 12 months of the end of the reporting year.
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Notification in Montenegro
No later than the day it files its corporate income tax return, the Montenegrin group member notifies the Tax Administration which company in the group files the CbC report and in which jurisdiction. A new notification is filed only when this information changes.
Local filing of the CbC report itself is suspended for group members that are not the ultimate or surrogate parent company. Montenegro signed the CbC MCAA on 14 May 2024; the OECD's review for 2025 describes it as a jurisdiction that does not yet receive CbC reports from other countries.
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What a CbC report contains
A CbC report aggregates the group's financial data for each jurisdiction in which it operates.
Revenue (from related and unrelated parties).
Profit or loss before tax.
Corporate income tax paid and accrued.
Number of employees, stated capital, accumulated earnings and tangible assets.
List of entities and their main activity by jurisdiction.
IVMethodology
No later than the day it files its corporate income tax return, the Montenegrin group member notifies the Tax Administration which company in the group files the CbC report and in which jurisdiction.
Notification in Montenegro
VIFee
CbC notification in Montenegro
from €600
CbC notification in Montenegro · 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
VIIIQuestions
Questions clients ask about this topic
We are a local subsidiary in Montenegro. Do we have to file the CbC report ourselves?
No, if the Montenegrin company is not the ultimate or surrogate parent company: local filing is suspended. The obligation is a notification to the Tax Administration no later than the day the corporate income tax return is filed.
What if the group has less than €750 million of revenue?
You have no CbC reporting obligation, but you must still have transfer pricing documentation under Art. 38c of the Law and Art. 10 of the Instruction.
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.