Liechtenstein Expands Double Taxation Agreement Network: Liechtenstein and Montenegro Sign DTA
On 25 September 2025, Liechtenstein and Montenegro signed a double taxation agreement (DTA).
The agreement governs the elimination of double taxation in cross-border situations. It is based on the OECD international standard and takes into account the requirements of the OECD/G20 BEPS (Base Erosion and Profit Shifting) project aimed at preventing tax avoidance and tax evasion in a cross-border context.
The agreement covers the avoidance of double taxation with respect to income and wealth taxes. To promote cross-border investment, the DTA reduces withholding taxes on dividends, interest, and royalties. If Montenegro joins the European Union, withholding tax on qualifying group dividends will no longer apply, thereby promoting investment within the internal market.
The DTA also clarifies the treaty treatment of asset structures, investment funds, pension funds, and non-profit organizations. To resolve complex double taxation cases, the agreement includes provisions for a mutual agreement procedure. The exchange of information is based on international standards.
The agreement represents another important step in the expansion of Liechtenstein’s DTA network. It is expected to increase legal certainty for investments and further strengthen economic and political cooperation between Liechtenstein and Montenegro.
Click here for the government press release.
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