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. The main features of the Double Tax Treaty Malta Montenegro are as follows:

Montenegrin Withholding Taxes

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.

Please contact us should you require any more information on the Malta Montenegro Double Tax Treaty and the unique tax planning opportunities that may arise. You can email us on enquiries@papilioservices.com or call us directly on +356 2258 2000.


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