Global Daily Tax News, Montenegro Set To Ratify The BEPS MLI, (Dec 24, 2025)

The Government of Montenegro has approved legislation for the ratification of the BEPS multilateral instrument, which the nation signed up to on November 12, 2025.

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 April 1, 2026, if the nation deposits its instrument of ratification with the OECD during December 2025.

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 upon entry into effect of the BEPS MLI for Montenegro.

Montenegro has selected 40 treaties as "covered agreements" for purposes of the BEPS MLI. This list will be confirmed when Montenegro ratifies the BEPS MLI.