Montenegro Draft Law for a Qualified Domestic Minimum Top-up Tax

The Government of Montenegro has published a draft Global Minimum Corporate Tax Law from the Ministry of Finance, which provides for the introduction of qualified domestic minimum top-up tax (QDMTT) to achieve a minimum effective tax rate of 15% in line with the Pilar 2 GloBE rules. As drafted, the QDMTT will apply to constituent entities of large MNE or domestic groups meeting an annual group revenue threshold of EUR 750 million in at least two of the previous four fiscal years. When requir…