So strukturieren Sie eine Holdinggesellschaft in Montenegro
As businesses grow and scale internationally, managing subsidiaries, intellectual property, and real estate assets through a centralized holding structure becomes highly advantageous. Montenegro is increasingly chosen as an alternative holding jurisdiction due to its corporate tax structure, Euro economy, and extensive Double Tax Treaty (DTAA) network.
Key Advantages of a Montenegrin Holding Structure
Structuring a holding company in Montenegro offers several financial and legal benefits:
- Low Corporate Income Tax: Taxable income is taxed on a progressive scale starting at just 9% (up to €100,000) and capping at 15% for profits over €1,500,000.
- Dividend Tax Exemption: Dividends received by a Montenegrin holding company from a local subsidiary are exempt from corporate income tax.
- Capital Gains Exemption: Capital gains realized from the sale of shares in foreign subsidiaries may be exempt from corporate income tax under specific participation exemption rules.
- No Currency Risk: Since Montenegro uses the Euro as its official currency, holding structures avoid currency fluctuations when dealing with EU subsidiaries.
Double Taxation Avoidance Agreements (DTAA)
Montenegro has over 45 active Double Taxation Avoidance Agreements with major global jurisdictions, including the UK, Germany, France, Italy, and China. These treaties allow a Montenegrin holding company to receive dividends, interest, and royalties from foreign subsidiaries with reduced or zero withholding tax rates.
Steps to Set Up the Holding Structure
- Incorporate the Holding Entity: Register a D.O.O. with the Central Registry in Podgorica. Specify “Holding Activity” as the primary business classification.
- Transfer Share Ownership: Structure the holding company to own at least 10% of the share capital in active subsidiaries to qualify for participation exemptions.
- Open Corporate Accounts: Establish banking relations with reputable Montenegrin banks capable of processing international transfers.
- Draft Corporate Agreements: Standardize transfer pricing and inter-company lending policies to comply with local transfer pricing regulations.
