Video Briefing

Offshore Citizen: Montenegro is Increasing Taxes (Progressive Tax Rate is Introduced)

Feb 16, 2022Video Briefing5:27Watch on YouTube

Montenegro has moved away from its long-standing 9% flat tax model, introducing a more progressive tax structure under the “Europe Now” program. The changes affect personal income, capital income, business profits, labor costs, minimum wages, and some non-resident digital work.

Montenegro, located on the Adriatic Sea south of Croatia and north of Albania, had been one of Europe’s lower-tax jurisdictions. Its 9% flat tax made it relatively simple and internationally competitive compared with many European alternatives.

That system changed at the end of 2021, when new policies were introduced under the Europe Now program.

The reforms include several major changes:

  • the minimum wage increased from €250 per month to €450 per month;
  • the personal tax system became more progressive;
  • some income from capital and passive sources increased to 15%;
  • corporate tax became progressive;
  • mandatory health contributions were eliminated;
  • employer labor-cost burdens were reduced;
  • a tax exemption was introduced for some non-residents working electronically for foreign employers.

Personal income tax changes

Under the new structure, the first €700 is tax-free. Above that, income is taxed under a progressive structure, with the normal 9% rate applying within the lower taxable range.

The transcript is unclear on the exact full personal income tax bands beyond the €700 threshold, but it states that the system is no longer the simple 9% flat model that previously made Montenegro especially attractive.

Capital income and passive income

Several types of non-salary income are now taxed at 15%. These include:

  • passive income;
  • capital gains;
  • income from capital;
  • income from intellectual property.

This represents a six-percentage-point increase from the former 9% rate. The transcript compares this with countries such as Lithuania, where a 15% rate may also apply, arguing that Montenegro’s previous tax advantage is now less compelling.

Corporate tax changes

Corporate tax is now progressive rather than a flat 9%.

The stated bands are:

  • 9% on the first €100,000 of profit;
  • 12% on profit from €100,000 to €1.5 million;
  • unclear rate above €1.5 million, because the transcript cuts off before giving the number.

For small businesses, the change may not have a major effect if profits remain below €100,000. As a business grows, however, the higher bands become more relevant.

Labor costs and employer contributions

One offsetting change is the elimination of mandatory health contributions.

The transcript states that employer labor-related contributions were reduced from about 39% to around the low-20% range for lower-wage workers, rising to around 31% for wages above €2,000 per month.

This means the reforms are not simply a tax increase across the board. Montenegro raised some taxes while also reducing certain labor costs for employers.

Political uncertainty

The reforms were introduced after Montenegro’s long-time leader Milo Đukanović’s government was removed from power in 2020. The replacement government was described as a complex coalition, which later collapsed, leading toward another election.

The transcript suggests there may be uncertainty about whether the policies will remain unchanged, depending on the outcome of future political changes.

Digital nomad-style exemption

One favorable development is a rule for non-residents. Non-residents must pay tax on work performed inside Montenegro, but the transcript states that they do not pay tax if they are doing work electronically for a foreign employer.

This effectively creates a tax exemption for some digital nomads or remote workers, depending on their facts.

The transcript notes that future visa policy remains unclear, but the tax treatment could become part of a broader attempt to attract remote workers, similar in concept to countries such as Costa Rica.

Practical implications

Montenegro may still be attractive for some residents, business owners, and remote workers, but it is no longer the same simple 9% flat-tax jurisdiction it was before.

The main decision points are:

  • whether income is salary, business profit, capital income, or foreign remote-work income;
  • whether a business earns under or above €100,000;
  • whether the person is resident or non-resident;
  • whether work is performed for a Montenegrin or foreign employer;
  • whether reduced labor contributions offset higher tax rates.

For small businesses and certain remote workers, Montenegro may remain competitive. For investors or business owners with significant passive income, capital gains, intellectual property income, or larger company profits, the new rules may reduce its appeal compared with the previous flat-tax regime.