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Montenegro & Malta Double Tax Treaty
The Double Taxation Relief Treaty between Malta and Montenegro was signed at Marseilles on 4 November 2008 and is currently in force since 23 September 2009.

Montenegrin Withholding Taxes
The main features of the Malta-Montenegro tax treaty are as follows:
Dividend Income
The Double Tax Treaty Malta Montenegro states that the maximum Montenegrin withholding tax on dividends distributed by a Montenegrin resident company to a Maltese resident company where the Maltese resident company holds at least 25% of the share capital of the Montenegrin resident company is 5%. In all other cases, the maximum Montenegrin withholding tax is 10%.
Interest Income
The Double Tax Treaty Malta Montenegro sets out a maximum Montenegrin withholding tax of 10% on interest paid by a Montenegrin resident to a Maltese resident beneficial owner of the interest income.
Royalty Income
The Double Tax Treaty Malta Montenegro sets out a maximum Montenegrin withholding tax of: – 5% on royalties paid for the use of, or the right to use, any copyright of literary, artistic or scientific work (including cinematograph films or films or tapes used for radio or television broadcasting) – 10% on royalties paid for the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience by a Montenegrin resident to a Maltese resident beneficial owner of the royalty income.
Other Income
The Double Tax Treaty Malta Montenegro states that pensions and other similar remuneration from Montenegrin sources to a Maltese resident individual may only be taxed in Malta.
However, this does not apply for pensions paid by under the social security legislation of the Montenegrin state, which are taxable in Montenegro only.
When navigating tax matters from Malta to Montenegro and from Montenegro to Malta, it’s essential to understand how the Double Tax Treaty between the two countries impacts taxation on income, capital gains, and other financial obligations. This treaty ensures that individuals and businesses benefit from reduced tax liabilities and avoid the risk of double taxation. By leveraging this agreement, both residents and companies can optimise their tax position when operating or investing across Malta to Montenegro or Montenegro to Malta. Please contact us should you require any more information on the Malta-Montenegro Double Tax Treaty and the unique tax planning opportunities.
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