Global Daily Tax News, Montenegro Ratifies The BEPS Multilateral Instrument, (May 21, 2026)

The Government of Montenegro has deposited its instrument of ratification with the OECD to ratify the BEPS multilateral instrument.

The MLI was developed through negotiations involving more than 100 countries and jurisdictions. It enables countries to modify their existing tax treaties to include measures developed under the OECD/G20 BEPS project without having to individually renegotiate these treaties.

The instrument will implement minimum standards to counter treaty abuse, prevent the artificial avoidance of permanent establishment status, improve dispute resolution mechanisms, and neutralize the effects of hybrid mismatch arrangements.

The BEPS MLI will come into effect for Montenegro's treaties from the first day of the fourth month following the country depositing its instrument of ratification – that is, from September 1, 2026.

Jurisdictions may choose, when ratifying the BEPS MLI, which of their treaties they wish to amend through the MLI. These treaties are known as "covered agreements".

Providing the other signatory territory has also selected that agreement as a covered agreement and the BEPS MLI has entered into force for that other signatory territory, the changes will be effective immediately from the date the MLI becomes effective for Montenegro.

Montenegro has selected 40 of its treaties as "covered agreements" for purposes of the BEPS MLI.