Montenegro brings its PIDP GloBE Information Return rulebook into force

Montenegro’s Ministry of Finance has brought into force a detailed rulebook prescribing the country’s Pillar Two information return. The Rulebook on the detailed manner of reporting top-up tax and the form and content of the top-up tax information return was published in Official Gazette No. 143/2026 on 1 October 2026 and entered into force on 9 October under Article 13.

The Rulebook implements the delegation in Article 28(9) of Montenegro’s Law on the Global Minimum Tax on Corporate Profits. It does not create a new top-up tax, change the 15% minimum rate or alter the statutory 18-month filing deadline. Instead, it converts the information-return obligation described in our March analysis of the enacted law into an operational reporting framework: Form PIDP, electronic XML filing, a filer notification and rules for central filing, fallback filing and exchange.

Who must file

Article 3(1) states that every constituent entity within scope of the GloBE rules is an information-return filer, including other special legal forms belonging to an MNE group or large domestic group. That rule sits alongside Article 28(2) of the Act, which permits a Montenegrin constituent entity or a designated domestic entity to submit the return.

Article 3(2) then preserves central-filing relief. A Montenegrin entity is not required to file locally where the ultimate parent or its designated filing entity files centrally in a jurisdiction that has a valid agreement with Montenegro between qualifying competent authorities for the relevant reporting fiscal year. The relief therefore depends on both a central filing and the necessary exchange relationship; the Rulebook does not make foreign filing alone sufficient.

A separate notification before the return deadline

Article 4 introduces an important procedural obligation. For the first reporting fiscal year, all Montenegrin constituent entities must notify the tax authority of the identity of the entity filing the return and the jurisdiction in which it is located. The notice is due at least 30 days before the information-return deadline. Under Article 4(2), it rolls forward automatically in later years until the group changes the named filer. Where the group has only one constituent entity in Montenegro, Article 4(3) requires the notice only for the first year.

The central-filing relief is backed by a local fallback. If the entity identified in the notice does not file the return, Article 4(4) reimposes the obligation on the Montenegrin constituent entity or responsible local entity. Article 5 provides for the tax authority to request local filing where a central return has not been received within the statutory period. These provisions are procedural additions to the Act’s central-filing exemption, not new charging rules.

Form PIDP and XML filing

Article 10 requires the return to be filed electronically, in XML, using Form PIDP annexed to the Rulebook. The annex occupies 30 of the instrument’s 35 pages. Its opening sections require identification of the filing entity, fiscal-year dates, amended-return status, consolidated-accounting standard and currency, ultimate-parent details, constituent entities and joint ventures. Later parts carry the jurisdictional calculation, top-up tax allocation, elections and other GIR information contemplated by Article 28(5) of the Act.

The prescribed form is therefore the GloBE information return, not merely a short domestic notice. Groups will need to reconcile the PIDP dataset with the OECD GIR architecture while preserving Montenegro-specific filer, tax-identification and exchange-jurisdiction fields.