1. Bilateral screening: Chapter 16 PRESENTATION OF MONTENEGRO Brussels, April 2013 M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Working Group for Chapter 16 – Taxation 1

2. CORPORATE PROFIT TAX AND COMPLIANCE WITH EU DIRECTIVES Milan Ivanović Senior Advisor Tax Administration TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 2

3. The legal framework LAW ON CORPORATE PROFIT TAX ("Official Gazette of RMN", no. 65/01 and 80/04 and "Official Gazette of MN", no. 40/08, 86/09 and 14/12) LAW ON COMPANIES – BUSINESS ORGANIZATIONS ("Official Gazette of RMN", no. 06/02 and "Official Gazette of Montenegro", no. 17/07, 80/08, 40/10, 36/11) TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 3

4. TAXPAYER A taxpayer of the Profit Tax shall be a resident or non-resident legal entity, which carries out a for-profit activity. A resident legal entity shall be an entity established in Montenegro, or having registered office with actual headquarters and control on the territory of Montenegro. A non-resident legal entity shall be an entity that is not established in Montenegro, and without registered office having actual headquarters and control in Montenegro, but that carries out its operations through a permanent establishment. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 4

5. Form of organization taxpayers Legal person who pays income taxes is organized as follows: Limited partnership Joint stock company Limited liability company Foreign company branch (permanent establishment). TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 5

6. OBJECT OF TAXATION The object of taxation of a resident shall be the profit that the resident generates in Montenegro and outside of Montenegro. The object of taxation of a non-resident shall be the profit that the non-resident generates in Montenegro. The object of taxation of the non-resident’s permanent establishment shall be the profit generated by such establishment. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 6

7. TAX RATE AND TAX BASE The rate of the Profit Tax shall be proportional and amounts to 9% of the tax base; tax rate is the same for all types of income. A taxable profit of a taxpayer shall represent the tax base of the Profit Tax. For establishing taxable profit, revenues and expenses in the amounts set forth in the income statement, in accordance with the law which regulates accounting and international standards, shall be recognised when assessing the taxable profit, with the exception of revenues and expenses for which the law prescribes a different method of calculation. Residents and non-residents have the same tax treatment in MN for taxation in respect of determining the tax base and tax rates. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 7

8. Exemption of income Revenue from dividends and profit shares of other legal entities are exempt from the tax base of the recipient, if the payer is subject to income tax under this Law. Tax exemptions State authorities, state administration authorities, local self- government authorities, public funds, public institutions, tourism organisations, sports clubs, sports associations and federations, religious communities, arts associations, political parties, chambers, trade unions and non-governmental organisations, do not pay the Profit Tax if they are established under a special law to carry out a non-profit activity. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 8

9. Not Deductible Expenses The following shall not be recognized as expenses: costs incurred for the purposes other than carrying out the business activity; costs that cannot be documented; interests on untimely paid taxes and contributions; interests paid to non-residents, if paid at the rate higher than customary commercial rate; administrative costs paid by a permanent establishment to the non resident headquarter; earnings of employees or other persons arising from profit sharing; pecuniary fines and penalties; correction of value of individual claims in a case of parties to which is simultaneously owed to; contributions given to political organizations. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 9

10. Expenses recognized to a certain amount Depreciation is recognized as an expense to the amount determined in accordance with the Law on Corporate Income Tax and Regulation on the classification of fixed assets by groups and methods for determining depreciation Up to 3.5% of total revenue are recognized expenses for health, education, scientific, religious, cultural, sports and charity, and for the protection of the environment, Up to 1% of total revenue are recognized representation expenses when they are incurred for business improvement, that they are documented and their recipient is not a related party. Up to 0.1% of the total revenue are recognized expenses for membership fees to chambers, unions and associations, except for the membership fees the amount of which is stipulated under a law, which is recognized in the amount prescribed by law. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 10

11. Update (written off value of) doubtful claims is recognized as an expense, provided that the taxpayer presents evidence of unsuccessful collection of such claims. Provisions (reserves) are recognized as expenses up to the amount established by special laws. Interests and appurtenant costs due to a creditor with the status of a related party shall be recognized as an expense in the amount not exceeding interests costs in the open market, if such costs do not exceed the actually paid amount. The difference between interest calculated on the arm’s length basis and the amount of interest actually received shall be included in the tax base of the recipient of such interest. Expenses recognized to a certain amount (cont.) TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 11

12. Capital gain shall be considered to be the revenue that a taxpayer generates through sale or other transfer for consideration of land, building constructions, property rights, equity interest, and securities. Capital gain shall represent the difference between the sale price and its acquisition price. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Capital Gains and Losses 12

13. The sale price of the asset shall be considered to be the market value of the asset received as monetary or non-monetary consideration reduced by the costs of sale or costs of other transfer of the asset. The acquisition price of the asset shall be the price at which the taxpayer acquired the asset or the estimated fair value of the asset, determined in accordance with the regulations governing accounting, reduced by depreciation costs established in the manner envisaged under this Law. Capital losses may be offset against capital gains realized in the same year. If even upon the offset against capital gains generated in the same year the capital loss still occurs, the taxpayer may carry forward the capital loss against future capital gains in the next five years. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Capital Gains and Losses (cont.) 13

14. Tax Treatment of Operating Losses Losses resulting from business relations, excluding those resulting in capital losses, may be carried forward against profit generated in future assessment periods, but not exceeding five years. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 14

15. TAX RELIEVES Newly established legal entity in economically underdeveloped municipalities conducting a production activity shall have the assessed profit tax for the period of the first eight years reduced by 100%. The tax holiday also applies on profit generated by the taxpayer in a newly established business unit conducting the production activity in an underdeveloped municipality proportionally to the share of generated profit of such business unit in the total amount of taxpayer’s profit. The tax credit is realized provided that a separate recording of operations of the business unit in the underdeveloped municipality is kept. The first year within which the right to tax holiday is exercised commences as of the day of registration in the register of legal entities. The tax relief does not apply to a taxpayer operating in the sector of primary production of agricultural products, transport or shipbuilding, fisheries and steel. 15 TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 15

16. TAX RELIEVES - continued Legal entity created by merging or division of an existing legal entity, or a legal entity established as a result of any status change is not considered a newly established legal entity. Legal entity is not considered a newly established legal entity if it ceased to exist within the period of three years preceding the establishment of such legal entity, or terminated its operations in the same or similar business activity. Newly established legal entity is not entitled to the tax relief if a related party is its founder or co-founder 16 TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 16

17. 17 Relief for NGO The tax base of a legal entity - a non-governmental organization, registered to carry out economic activities shall be reduced by 4,000 euro provided that uses the profit for realization of objectives for which it has been established. Deduction shall be recognized up to the amount of the tax base. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation

18. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Council Directive 2009/133/EC of 19 October 2009 on the common system of taxation applicable to mergers, divisions, partial divisions, transfers of assets and exchanges of shares concerning companies of different Member States and to the transfer of the registered office of an SE or SCE between Member States Compliance with directives related to corporate income taxes 18

19. The legal framework LAW ON CORPORATE PROFIT TAX ("Official Gazette of RMN", no. 65/01 and 80/04 and "Official Gazette of MN", no. 40/08, 86/09 and 14/12) LAW ON COMPANIES – BUSINESS ORGANIZATIONS ("Official Gazette of RMN", no. 06/02 and "Official Gazette of Montenegro", no. 17/07, 80/08, 40/10, 36/11) TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 19

20. A company can be restructured as follows: the merger; division into two or more companies; separation by formation of one or more companies. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation The restructuring of the Joint Stock Company (Article 22 of the Company Law) 20

21. Restructuring of a joint stock company by merger can be done when one or more companies join the existing company by transferring the entire assets and liabilities to that company which in exchange issues shares to the shareholders of the companies being merged. Also merger is considered when two or more companies merge into a newly formed company that issues shares of the newly formed company to the shareholders of the companies being merged. The surviving company, or the newly founded company, shall be known as the recipient company, whereas the company transferring assets and liabilities shall be known as merged company. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Merger of Companies 21

22. A joint stock company shall cease to exist by restructuring by way of division, by transferring entirely its assets and liabilities to two or more existing or newly formed companies, which will in exchange issue shares that are distributed to shareholders of the dividing company. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Division of Companies 22

23. The restructuring of the shareholding company through division by formation of one or more companies existing company transfers part of its assets and liabilities to one or more companies that are established (the new company), and it in exchange issues stock to shareholders of the existing company, whose capital is reduced by the value of the transferred assets. For these types of status changes (merger, division or partial division), it is prescribed that companies that have taken over the assets and liabilities of companies whose shareholders can use the property taken, in addition to shares, fair compensation, and the amount paid, provided that the amount does not exceed 10% of the nominal value of shares issued for property taken or accounting value, if the nominal value is not determined TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Division by forming one or more companies (partial division) 23

24. There are no legal provisions that define the exchange of shares as a status change. However, in practice there are cases like this and is treated as a form of issuing shares. Tax treatment of status changes (Article 26 of the Law on Income Tax) Transfer of assets in case of status change (acquisition, merger or division) and the distribution of the share capital, is not a sale of the property. Transfer of assets in the event of status changes is not subject to profit tax. Allotment of securities representing the capital of the transferee company or the acquirer of the company, to the shareholders of transferred or acquired company in exchange for securities representing the capital of the company transferred or taken over the company, does not cause the taxation. Exchange of shares TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 24

25. Right to defer payment of the Profit Tax on capital gains realized from the transfer of assets in case of status change shall be acquired in a case the owner of the legal entity which transferred the assets in the event of acquisition, merger, or division received a consideration in a form of shares or interest in the legal entity to which the assets were transferred, as well as in the case of possible cash consideration the amount which does not exceed 10% of the par value of acquired shares or interest. Tax liability for capital gains arise at the time when a legal entity, created by the status change, sells the assets taken over by the status change. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Right to defer payment of the Profit Tax 25

26. The tax treatment of provisions and reserves and the transfer of property of a permanent establishment Transfer of provisions and reserves is not regulated by tax law, but these transactions are not subject to corporate income tax. Transfer of business losses In the case of status changes, the transfer of operating losses is exempt from taxation. The tax benefits shall be proportionally divided according to the value of the assets, and the competent tax authority shall be notified thereof. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 26

27. The tax treatment of the transfer of property of a permanent establishment Transfer of property of a permanent establishment is not regulated by tax law, but these transactions are not subject to corporate income tax. The tax treatment of the transfer of the seat Transfer of the seat is not subject to taxation, and the tax law does not contain provisions which regulate this. The liquidation of the legal entity The case when the assets of a subsidiary are transferred to the parent company, the parent company is not obliged to determine capital gain or loss. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 27

28. Council Directive 2011/96/EU of 30 November 2011 on the common system of taxation applicable in the case of parent companies and subsidiaries of different Member States The legal framework LAW ON CORPORATE PROFIT TAX LAW ON COMPANIES – BUSINESS ORGANIZATIONS TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 28

29. Tax payment and tax return Income tax is calculated after the end of the financial year or other period for taxes, on the tax base realized in that period. Taxpayer is obliged to submit tax return to the competent tax authority. Tax return shall be filed no later than three months from the expiry of the period for which the tax is calculated. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 29

30. Parent company Parent company, by the Law on companies, shall mean the company having a majority ownership of or majority right to manage another company – subsidiary, while in the tax law there is no definition of the parent company. Daughter company also is not defined by tax law. The permanent establishment The permanent establishment shall mean a permanent place of operations wherein or through which a non-resident entirely or partly carries out its operations and is organized in one of the following forms: headquarters, branch, office, factory, workshop, mine, oil or gas deposit, quarry or any other place of exploitation of natural recourses. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 30

31. Dividend Dividend is income from a holding action, ie. the dividend is payment of the part of the accumulated net profit of the company to its shareholders. from shares or other rights, not being debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. In tax law there is no definition of dividends, and in agreements on avoidance of double taxation dividend is defined as an income from shares or other rights, not being debt claims, participating in profits, as well as income from other corporate rights which is subjected to the same taxation treatment as income from shares by the laws of the State of which the company making the distribution is a resident. Share in profit Share of profit is the income of limited liability companies and limited partnerships, and in tax law there is no definition of share in profit. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 31

32. Withholding tax A taxpayer of the Profit Tax shall be obliged to calculate, withhold and pay the withholding tax on payments made on the dividends and share in profits paid to the resident and non-resident legal entities and natural persons. If the firm's daughter (resident of Montenegro) pays dividends or profit shares to parent company (non-resident legal entity) it has to calculate withholding tax, and also when the payment is made between resident legal entities, unless the agreement on avoidance of Double Taxation is otherwise regulated. Exemption from withholding tax on dividends Permanent establishment of the non-resident legal entity does not calculate and not withold the withholding tax on dividends or profit shares paid to non-resident legal entities. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 32

33. The right to a tax credit The assessed profit tax of a parent company – a resident taxpayer in Montenegro may be reduced by the amount that corresponds to a tax paid by its non-resident affiliation in another country on dividends being included in the revenues of the parent company. Revenues from dividends from a non-resident affiliation shall be included in the revenues of a resident parent company in the amount increased by the paid withholding tax on disbursed dividends. The tax credit may be used to reduce the assessed tax of the parent company, in the amount not exceeding the tax that would have been assessed on profit or on dividend under the provision of this Law. Unused part of the tax credit may be carried forward against the tax of the parent company to forward assessment periods, but not exceeding five year. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 33

34. The right to a tax credit (continued ) Parent company which has uninterruptedly, for a period of at least one year preceding the submission of a tax return, owned 10% or more shares or interest of a non-resident affiliation shall have the right to a tax credit. Parent company shall be obliged to submit relevant proofs on the size of its holding in capital of a non-resident affiliation, duration of such holding and tax paid to another country by the affiliation, along with its income statement, to a competent tax authority. Profit of a Permanent Establishment of Resident Taxpayer For a resident taxpayer that generates profit outside of Montenegro and pays a tax on such profit in another country the tax credit shall be approved at the account of the profit tax assessed in accordance with the provision of the Montenegrin Law in amount equal to the amount of the profit tax paid in such country. The tax credit cannot exceed the amount that would be calculated by applying tax rate od 9% (the provisions of this Law) on the profit generated in another country. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 34

35. Council Directive 2003/49/EC of 3 June 2003 on a common system of taxation applicable to interest and royalty payments made between associated companies of different Member States The legal framework LAW ON CORPORATE PROFIT TAX LAW ON TAX ADMINISTRATION LAW ON COMPANIES – BUSINESS ORGANIZATIONS LAW ON COPYRIGHT AND RELATATED RIGHTS TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 35

36. Withholding tax A taxpayer of the Profit Tax shall be obliged to calculate, withhold and pay the withholding tax on payments made on interest, royalties, and other intellectual property rights compensations, paid to a non-resident legal entity. When permanent establishment of nonresident legal entity paying of interest and royalties has to pay withholding tax, except in case where the consideration is attributed as revenue of that establishment. Interest In tax law, there is no definition of interest, and in agreements on avoidance of double taxation of interest is defined as “income from debt claims of every kind, whether or not secured by mortgage and whether or not carrying a right to participate in the debtor's profits, and in particular, income from government securities and income from bonds or debentures, including premiums and prizes attaching to such securities, bonds or debentures as well as other income assimilated to income from money lent by the laws of the State in which the income arises but does not include any income which is treated as a dividend. Penalty charges for late payment shall not be regarded as interest.“ TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 36

37. Copyright act (work) Pursuant to the Law on Copyright and Related Rights the copyright acts (works) are considered: 1) Voice works; 2) written works; 3) musical works, with or without words; 4) dramatic, dramatic-musical, choreographic, puppetry and pantomime works; 5) photographic works and works created by a process similar to photography; 6) audiovisual works; 7) works of fine art; 8) architectural works; 9) works of applied art and industrial design; 10) cartographic works; 11) presentation of scientific, educational or technical nature. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 37

38. Royalties Royalties is one of the property rights of the author. For every use of copyrighted works by other entities, the royalty payment or just compensation belongs to the author. In tax law, there is no definition of "royalties" The agreements on the avoidance of double taxation, royalties are defined as "payments of any kind received as a consideration for the use of, or the right to use: 1) any copyright of literary, artistic or scientific work (including cinematographic films and recordings on tape or other media used for radio or television broadcasting or other means of reproduction or transmission); 2) any patent, trade mark, 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. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 38

39. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Related Persons The definition of Related persons is prescribed by Article 15 of the Law on Tax Administration. Related persons shall be considered the persons having special mutual relations that may have a direct impact on the conditions or economic results of transactions between them. The special relations shall include individual relations between: - the persons having at least 25% of share in the capital of another person; - one person that has a direct or indirect interest in another person which is a company, if such an interest is at least 25%; - one person that is subordinate to the other person in terms of his business position and that other person, or one person that is under control (directly or indirectly) of the other person and that other person; - the persons representing subsidiaries or are under direct or indirect control of a third person; - the persons that directly or indirectly control a third person and that third person, if each person’s voting right is at least 25%. 39

40. Tax rate The withholding tax shall be paid at the rate of 9% to a base made of the gross revenue. Recording of withholding tax Rulebook on form and content of reports on calculated and paid withholding tax on income created by non-resident legal entity prescribed a special report (Form IOPP) to suspend the withholding tax for payments to non-residents, which the payer is obliged to submit to the tax authority by the end of February of the current year for the previous year. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 40

41. No discrimination Resident companies are taxable on their world wide income. Non-resident companies are taxable on income generetad in Montenegro. The corporate income tax rate is the same on all types of income. The tax rate of 9% applies to all types of revenues, which represents a general corporate profit tax rate. The same corporate profit tax rate applies to all taxpayers of the corporate profit tax.. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 41

42. No discrimination For all legal entities the same method of calculating the tax base is applied (On slides 7-11 of this presentation we presented the method of determining and calculation of the tax base, exemption of income, the list of non- didactible expenses, the list of expenses recognized to de certain amount). Tax base is taxable profit (Income – Expenses) Residents and non-residents have the same tax treatment in MN for taxation in respect of determining the tax base and tax rates; In Montenegro there are no rules of Code of conduct that apply to business taxation. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 42

43. No discrimination Provisions relating to different tax treatment of non-residents compared to residents do not exist in Tax law. The Law on corporate profit tax does not have specific provisions dealing with determining the tax base for specific types of taxpayers (e.g. investment companies, non-resident legal entities), but all legal entities have the same treatment for determining the tax base. In Montenegro, there is no favoring of non-residents compared to residents. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 43

44. Tax exemptions and tax relieves The list of legal entities which do not pay income tax (State authorities, state administration authorities, local self-government authorities, public funds etc.) is shown on slide number 8. Law on corporate income tax provides two tax relieves related to: - newly established production companies in underdeveloped municipalities; - NGOs (shown on slide number 16-18). The purpose of the tax relief for newly established production companies in underdeveloped municipalities is to encourage and stimulate economic growth and investments in these municipalities. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 44

45. TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation Thank you for your attention! QUESTIONS 45

46. Contact: Milan Ivanović poreska.uprava@tax.gov.me Tatjana Bošković tatjana.boskovic@mif.gov.me TAXATION Chapter 16: M O N T E N E G R O Negotiating Team for the Accession of Montenegro to the European Union Chapter 16: Taxation 46